United States District Court, D. Nevada
WILLIAM J. GEDDES KRISTEN R. GEDDES THE GEDDES LAW FIRM,
P.C.Attorneys for Defendant Intelli-Heart Services, Inc.
GEDDES LAW FIRM, P.C. KRISTEN R. GEDDES Attorneys for
Defendant Intelli-Heart Services, Inc.
DEFENDANT INTELLI-HEART S ERVICES, INC'S MOTION
FOR ENLARGEMENT OF TIME TO ANSWER OR RESPOND TO
PLAINTIFF'S SECOND AMENDED COMPLAINT [FIRST
NOW Defendant Intelli-Heart Services, Inc. ("IHS"),
by and through its counsel William J. Geddes, Esq., and
Kristen R. Geddes, Esq., of The Geddes Law Firm, P.C, and
herein files Defendant Intelli-Heart Services, he's
Motion for Enlargement of Time to Answer or Respond to
Plaintiffs Second Amended Complaint [First Request].
This motion is based upon the following Points and
Authorities, the pleadings and papers on file in this action,
and any oral arguments the Court may entertain at any hearing
set for this matter.
OF POINTS AND AUTHORITIES
federal diversity-jurisdiction action asserts state-tort
claims arising from an unauthorized and clandestine agreement
between Plaintiff, Terrance Walker, and James Winters, a
distributor for Defendant IHS. See generally, Second
Amended Complaint, ECF 136.
Amended Complaint (ECF 004), Plaintiff asserted a
claim against IHS for tortious interference with Walker's
contractual relationship with Winters. Id. IHS
appeared in this matter and answered Plaintiffs Amended
Complaint, denying Plaintiffs allegations. Amended
Answer to Amended Complaint, ECF 026.
April 9, 2019, the Court granted Walker leave to file a
Second Amended Complaint (ECF 135), and the
Second Amended Complaint was filed that date. ECF
136. Accordingly, IHS, who is already a party to this action,
was served on that date. Pursuant to Fed.R.Civ.P. 15(a)(3)
IHS' deadline to answer or respond to the Second
Amended Complaint is April 23, 2019.
Second Amended Complaint added three new defendants
and four additional causes of action. See ECF 136.
On information and belief, Defendants Vanessa Parsons and
Danny Weisberg were served with Plaintiffs Second Amended
Complaint on April 18, 2019, making their deadline to
answer or respond, May 9, 2019. Fed.R.Civ.P. 15(a)(1)(B).
Good Cause Exists to Grant the Instant Enlargement
of Time. Which IS Not Made For The Purpose of Delay.
Civ. P. 6(b) addresses extending time, stating:
(1) In General.
When an act may or must be done within a specified time, the
court may, for good ...