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RB Products, Inc. v. Ryze Capital, L.L.C.

United States District Court, D. Nevada

May 31, 2019

RB PRODUCTS, INC., Plaintiffs,
v.
RYZE CAPITAL, L.L.C.; ENCORE DEC, L.L.C.; RYZE RENEWABLES RENO, L.L.C.; RYZE RENEWABLES, L.L.C.; MICHAEL BROWN; CHRIS DANCY; RESC, L.L.C.; RYZE RENEWABLES LAS VEGAS, L.L.C.; MATT PEARSON; AND RANDY SOULE, Defendants.

          Adam Hosmer-Henner, Esq, McDONALD CARANO, Ashish Mahendru, Darren A. Braun, ATTORNEYS FOR PLAINTIFF.

          DICKINSON WRIGHT, PLLC, John P. Desmond, LATHAM & WATKINS LLP, Joshua G. Hamilton, Attorneys for Defendants Ryze Capital Partners, L.L.C., Ryze Renewables Las Vegas, L.L.C., Chris Dancy and Matt Pearson.

          LAXALT & NOMURA LTD, Attorney for Defendants, Ryze Renewables L.L.C., Ryze Renewables, Reno, L.L.C.,

          HOLLEY, DRIGGS, WALCH, FINE, PUZEY, STEIN & THOMPSON, Attorney for Defendants Randy Soule, RESC, LLC, and Encore DEC, LLC.

          KOCH & SCOW, LLC, David R. Koch, GARCIA RAINEY BLANK & BOWERBANK, LLP, Jeffrey M. Blank, Norma V. Garcia, Attorneys for Defendant Michael Brown.

          PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTIONS TO DISMISS AND MOTION TO STAY FIRST REQUEST

          HON. MIRANDA M. DU UNITED STATES DISTRICT JUDGE.

         Plaintiff RB Products, Inc. (“RB Products”) files this Motion for Extension of Time to Respond to Defendants' various motions identified below, and requests that it be permitted until June 30, 2019 to file responses. As discussed further below, good cause exists for this extension.

         Plaintiff respectfully requests an extension through the end of June 30, 2019 to respond to Defendants' following motions:

Party

Pleading

Document

Encore, RESC, Soule

Soule Defendants' Motion to

Dismiss Amended Complaint

47

Encore, RESC, Soule

Soule Defendants' Answer to

Amended Complaint

48

Ryze Capital, Ryze Las Vegas,

Dancy, Pearson

Motion to Stay Plaintiff's Claims

Pending Arbitration

51

Ryze Capital, Ryze Las Vegas,

Dancy, Pearson

Ryze Capital Defendants' Motion

to Dismiss and Memorandum of

Points and Authorities In Support

Thereof

52

Ryze Reno, Ryze Renewables

Joinder to Motion to Stay

Plaintiff's Claims Pending

Arbitration

53

Ryze Reno, Ryze Renewables

Joinder to Motion to Dismiss

Amended Complaint

54

Ryze Capital, Ryze Las Vegas,

Dancy, Pearson

Ryze Capital Defendants' Motion

to Dismiss and Memorandum of

Points and Authorities In Support

Thereof (Corrected Image re Dkt

52)

55

Michael Brown

Brown's Joinder to Motion to

Dismiss [52]

56

Michael Brown

Brown's Joinder to Motion to

Dismiss [47]

57

Michael Brown

Brown's Joinder to Motion to Stay

[51]

58

Michael Brown

Brown's Motion to Dismiss

Plaintiff's Amended Complaint

59

         Good cause exists for this extension because Plaintiff's lead counsel's firm, which consists of two lawyers, is scheduled to begin a jury trial on June 10, 2019 in the 284th District Court of Montgomery County, Texas. That trial is expected to last approximately one week, and will necessarily require trial preparation beforehand. Plaintiff's request for a 19-day extension for its responses is reasonable, as it would allow counsel to conclude that trial on or about June 17, 2019 and then start preparing Plaintiff's responses to the many pending motions.

         Plaintiff has conferred with the Defendants regarding this extension and a possible agreed briefing schedule but has been unable to reach a complete consensus.

         Defendants Ryze Capital Partners, Chris Dancy, Matt Pearson, Ryze Renewables Las Vegas, Ryze Renewables Reno, and Ryze Renewables are agreeable to Plaintiff's requested extension, with the proviso that their respective replies be due on July 26, 2019. Plaintiff is in agreement with this proviso.

         Conversely, Defendants Encore, Randy Soule, RESC, and Michael Brown stated that they are opposed to Plaintiff's request for an extension.[1]

         Due to the number of the pending motions-some of which will involve complicated issues of non-signatory arbitration law-and due to the fact that Plaintiff's lead counsel's firm will be in trial starting June 10th, Plaintiff contends that good cause exists to extend the time for Plaintiff to file its responses to the above-identified motions. Plaintiff respectfully requests this Court to grant ...


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