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Barcelon v. Landforce Corporation

United States District Court, D. Nevada

April 30, 2019

ROBERT BARCELON, an individual, Plaintiff,
v.
LANDFORCE CORPORATION individually; ALBERT LEON HARRIS, individually; DOES l-X; and ROES CORPORATIONS l-X, inclusive, Defendants.

          STOVALL AND ASSOCIATES Ross Moynihan, LESLIE MARK STOVALL, ESQ., Nevada Bar No. 2566, ROSS MOYNIHAN, ESQ., Attorneys for Plaintiff, Robert Barcelon

          BAUMAN LOEWE WITT & MAXWELL, PLLC Michael C. Mills, MICHAEL C. MILLS, ESQ., Nevada Bar No. 003534, Attorneys for Defendants, Landforce Corporation

          STIPULATION TO AMEND ANSWER

         COME NOW Plaintiff Robert Barcelon, by and through his counsel of record Ross Moynihan of Leslie Stovall, Esq. of Stovall & Associates and Defendant Albert Leon Harris by and through his counsel of record Michael C. Mills, Esq. of the law firm of Bauman Loewe Witt & Maxwell, and hereby agree and stipulate that Defendant Harris may file an Amended Answer to Plaintiff's Complaint.

         IT IS ORDERED that the parties' stipulation to amend answer (ECF No. 32) is GRANTED. IT IS FURTHER ORDERED that defendant's motion for leave to amend answer (ECF No. 30) is DENIED as moot.

         [PROPOSED] AMENDED ANSWER PLAINTIFFS COMPLAINT AND (JURY REQUEST)

         COMES NOW Defendant Albert Leon Harris, by and through his counsel of record, Michael C. Mills, Esq. of the law firm of Bauman Loewe Witt & Maxwell, PLLO, and hereby demands that all issues be presented to a jury, and admits, denies and otherwise files his Amended Answer to Plaintiff's Complaint as follows:

         PARTIES

         1. Answering Paragraph 1 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris is without sufficient information upon which to base a belief as to the truth or falsity of the allegations contained therein and upon said ground denies the same.

         2. Answering Paragraph 2 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris admits the allegations of this paragraph.

         3. Answering Paragraph 3 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris admits the allegations of this paragraph.

         4. Answering Paragraph 4 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris denies the allegations of this paragraph.

         5. Answering Paragraph 5 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris denies the allegations of this paragraph.

         JURIS1CTION

         6. Answering Paragraph 6 of Plaintiff's Complaint, this answering Defendant Albert Leon Harris admits ...


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