Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Pharmaplast S.A.E v. Zeus Medical Holdings LLC

United States District Court, D. Nevada

November 2, 2017

PHARMAPLAST S.A.E., an Egyptian share holding company, Plaintiff,
v.
ZEUS MEDICAL HOLDINGS LLC, et al., Defendants.

          James J. Ream, ESQ, Lawrence M. Boesch, Esq Pro Hac Vice Attorneys for Plaintiffs PHARMAPLAST S.A.E.

          STIPULATION TO CONTINUE TRIAL; [PROPOSED] ORDER

         WHEREAS the parties hereto, by and through their counsel of record, submitted a joint proposed pretrial order on May 10, 2017, and

         WHEREAS the Court, having considered the Joint Proposed Pretrial Order and having issued, on May 12, 2017, a Pretrial Order setting the above-captioned for jury trial on March 27, 2018 to commence at 9:00 a.m. in Las Vegas Courtroom 6D, The parties hereto having encountered obstacles with presenting the above-captioned cause for trial, do hereby present this stipulation for order continuing trial, as set forth in more particularity as follows:

1. Plaintiff PHARMAPLAST S.A.E. ("PHARMAPLAST") is an Egyptian share holding company with its headquarters in Alexandria, Egypt; although it makes sales in North America, its staff, employees and officers rarely travel to the United States, and wher they do, it is usually for a trade show in such places as Miami, Las Vegas and Los Angeles;
2. Default has been entered against defendant ZEUS MEDICAL HOLDINGS LLC, which is a dissolved Nevada limited liability company, and which has not participated in the above-captioned action since it was filed with this Court on Dec. 21, 2015 (ECF Nos. 19, 21, 25);
3. The above-captioned action was stayed as to defendant ROBERT DANIELS, a Nevada resident, as a result of his 8/31/16 filing of a petition in U.S. Bankruptcy court, Chapter 7 (ECF No. 41-42), his listing of the alleged debt to PHARMAPLAST as a nonpri-ority unsecured debt in his bankruptcy case, in his Schedule E/F on 9/13/16 in that case, and the Order of Discharge given to him in that case under 11 U.S.C. § 727 on Dec. 6, 2016;
4. Defendant DANIEL MULVANY resides in Kansas City, Kansas and has few contacts with the State of Nevada;
5. Defendant MARK BOLLING resides in Tampa Bay, Florida, and has few contacts with the State of Nevada;
6. PHARMAPLAST has no business interactions or contacts within the State of Nevada;
7. With the only defendants who have business in Nevada being either dissolved and defaulted (ZEUS MEDICAL HOLDINGS, LLC) or bankrupt with a discharge of the subject debt (ROBERT DANIELS), the parties hereto have nevertheless diligently prosecuted the above-captioned action through civil discovery originally set to close on Sept. 13, 2016 (ECF No. 34 at 2:7) but extended by court order on stipulation through Sept. 14, 2016 (ECF No. 40);
8. The parties hereto have met and conferred to find suitable dates that serve their interests practically with the least potential for inconvenience to each other and to counsel of record;
9. If the above-captioned action were to go to trial on March 27, 2018, it would be three hundred nineteen (319) days since the pretrial order that was issued on May 12, 2017 (ECF No. 56) setting it for trial;
10. Continuing this cause to July 9, 2018 would add another one hundred four (104) days to the length of time from the pretrial order, making the total amount of time from pretrial order to jury trial one (1) year and fifty-eight (58) days;
11. In entering into this Stipulation the parties hereto waive such claims, allegations or defenses as might otherwise be made on the basis of diligence in the prosecution of this action for grounds of moving for its dismissal; this stipulation is expressly conditioned on the Court's approval of the length of time between pretrial order and jury trial, in the absence of which this stipulation is ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.