Soto v. Aria Resort & Casino, LLC

          ROBERT A. RABBAT, ESQ. Nevada Bar No. 12633 TESS E. JOHNSON, ESQ. Nevada Bar No. 13511 ENENSTEIN RIBAKOFF LAVIÑA&PHAM Attorneys for Defendant Phillipe Rouas

          William Soto Plaintiff in Pro Se

          Lisa A McClane Jackson Lewis P.C. Attorneys for Defendant Aria Resort & Casino, LLC, Yong Hoon Lee, Jerald Hedrick, Robert Fishbourne, and Todd Owen

          Adam J. Breeden Breeden & Associates, PLLC Attorneys for Melanie Saljougui

          DEFENDANT PHILLIPPE ROUAS'S EX PARTE MOTION FOR ENLARGEMENT OF TIME TO MOVE, ANSWER, OR OTHERWISE RESPOND TO PLAINTIFF'S [44] FIRST AMENDED COMPLAINT

         Defendant PHILIPPE ROUAS (“Rouas”), by and through his counsel, the law firm Enenstein Ribakoff LaViña & Pham, hereby submits this Ex Parte Motion for Enlargement of Time to Move, Answer or Otherwise Respond to Plaintiff WILLIAM SOTO's (“Plaintiff”) First Amended Complaint. (ECF No. 44).

         This Motion is made and based upon the memorandum of points and authorities and exhibits attached hereto, all pleadings, declarations, affidavits, and other evidence on file in this action, and upon such oral argument and/or documentary evidence as may be presented at the hearing on this motion.

         DECLARATION OF ROBERT A. RABBAT, ESQ., PURSUANT TO LR 7-5(b) IN SUPPORT OF THE EX PARTE MOTION FOR ENLARGEMENT OF TIME

         I, Robert A. Rabbat, Esq., declare and say:

         1. I am an attorney licensed to practice law in all courts in the State of Nevada. I am a partner of the law firm Enenstein Ribakoff LaVina & Pham, counsel of record for Phillipe Rouas in this action. I have personal knowledge of all facts stated herein unless specifically stated upon information and belief. I am over the age of 18 and I am competent to testify hereto.

         2. I submit this declaration pursuant to Local Rule 7-5(b) and in support of Mr. Rouas' ex-parte motion for enlargement of time to file a motion, answer, or other response to Plaintiff's First Amended Complaint filed on May 23, 2016. (ECF No. 44).

         3. I was retained to represent Mr. Rouas today, December 12, 2016.

         4. Mr. Ruoas is currently living outside of the United States.

         5. Plaintiff's First Amended Complaint was served by publication in the Nevada Legal News from October 24, 2016 to November 21, 2016. (ECF No. 85).

         6. Mr. Ruoas only very recently learned of the service of Plaintiff's First ...