United States District Court, D. Nevada
JAMES PARSONS, individually and as Special Administrator of the Estate of Carolyn Lee Parsons, and ANN-MARIE PARSONS, Plaintiffs,
COLT'S MANUFACTURING COMPANY LLC, et. al., Defendants.
MATTHEW L. SHARP, LTD. Matthew L. Sharp, Richard H. Friedman,
Joshua D. Koskoff, Katherine L. Mesner-Hage, Counsel for
Bohman, Snell & Wilmer, LLP, Counsel for Defendants
Daniel Defense, Inc., Patriot Ordnance Factory, and
Michael Nunez, Murchison & Cumming, LLP, James Vogts,
Swanson, Martin & Bell LLP, Counsel for Defendant Guns
and Guitars, Inc.
H. Mowbray, Mary E. Bacon, Jessica Chong, Spencer Fane LLP,
Camden R. Webb, Justin S. Feinman, Turner A. Broughton,
Williams Mullen, PC, Counsel for Defendants FN America, FN
Herstal, and Herstal Group
FEARS & SCHUTTERT LLP, Jay J. Schuttert, Alexandria L.
Layton, Counsel for Defendants Colt's Manufacturing
Company, LLC, Colt Defense, LLC, Christensen Arms, Lewis
Machine & Tool Company, and LWRC International, LLC
F. Renzulli, Christopher Renzulli, Scott C. Allan, Renzulli
Law Firm, LLP, Counsel for Defendants Colt's
Manufacturing Company, LLC, Colt Defense, LLC, Lewis Machine
& Tool Company, and LWRC International, LLC
J. Benevento, Dorsey & Whitney, LLP, Counsel for
Defendant Christensen Arms
Amin, The Amin Law Group, Ltd., Christopher M. Chiafullo, The
Chiafullo Group, LLC, Counsel for Defendants Discount
Firearms and Ammo, LLC, DF&A Holdings, LLC, and Maverick
Anthony Pisciotti, Anthony Pisciotti, Pisciotti MalschCounsel
for Defendant Noveske Rifleworks, LLC
JOINT STIPULATION AND ORDER FOR EXTENSION OF TIME FOR
REMAINING DEFENDANTS TO FILE RESPONSE TO COMPLAINT (FIRST
Court entered an order on July 29, 2019 (ECF No. 25)
approving a stipulation (ECF No. 24) extending the deadline
for Defendants FN America, FN Herstal, and the Herstal Group
(collectively, the “FN Defendants”) to move,
respond, answer or otherwise plead to Plaintiffs'
Complaint to September 24, 2019.
James Parsons and Ann-Marie Parsons
(“Plaintiffs”), Defendants, Colt's
Manufacturing Company, LLC, Colt Defense, LLC, Daniel
Defense, Inc., Patriot Ordnance Factory, Noveske Rifleworks,
LLC, Christensen Arms, Lewis Machine & Tool Company, LWRC
International, LLC, Discount Firearms and Ammo, LLC, DF&A
Holdings, LLC, Maverick Investments, LP, Sportsman's
Warehouse, and Guns and Guitars, Inc. (collectively, the
“Remaining Defendants”), and the FN Defendants,
pursuant to Fed.R.Civ.P. 6(b)(1), LR IA 6-1 and 6-2, and LR
7-1, file this joint stipulation seeking the same September
24, 2019 deadline that applies to the FN Defendants as the
deadline by which the Remaining Defendants may move, respond,
answer or otherwise plead to the Complaint in this matter.
This is the parties' first request to extend the time for
the Remaining Defendants to respond to Plaintiffs'
Complaint. This requested extension of time is sought in good
faith and not for purposes of causing any undue delay. The
requested extension will result in the same deadline to
respond to the Plaintiffs' Complaint applying to all
defendants in this case.
parties have agreed that in filing this joint stipulation
that the Remaining Defendants have in no way impaired their
right to seek dismissal of this case on any grounds,
including lack of personal jurisdiction.
Plaintiffs and the Remaining Defendants respectfully request
that the Court enter an Order providing that the Remaining
Defendants have until September 24, 2019, to move, respond,
answer or otherwise plead to Plaintiffs' Complaint.