Lux Sterling Holdings, LLC v. Philip Whelan, Anthony Manerbino, Dawna Manerbino, Aaron Godbout, & CNW, LLC

Hon. Richard F. Boulware, II, District Court Judge

AVRAMSKI LAW, PC
Boris Avramski, Esq.
Nevada Bar No. 11350
602 South 10 Street
Las Vegas, NV 89101
Phone: (702) 522-1808
Fax: (702) 685-3625
bkhelpvegas@yahoo.com
Attorney for Plaintiff

UNOPPOSED MOTION TO EXTEND PLAINTIFF'S TIME TO RESPOND TO MOTION TO DISMISS

COMES NOW plaintiff Lux Sterling Holdings, LLC ("Sterling"), by and through its attorney of record, Boris Avramski, Esq., and hereby files this unopposed motion pursuant to Rule 6(b)(A)(1) to extend by two weeks Sterling's time to respond to the Motion to Dismiss or Transfer Action [Doc# 12] filed by defendants Philip Whelan, Anthony Manerbino, Dawna Manerbino, and CNW, LLC (the "Moving Defendants").

In support of this motion, Sterling states as follows:

1. The Motion to Dismiss or Transfer Action was filed on July 5, 2016 and Sterling's response is currently due on July 22, 2016. This unopposed motion seeks to extend that due date by two weeks, until August 5, 2016.

2. The extension is necessary in light of the following factors: (i) the number and complexity of the issues raised in the Motion to Dismiss or Transfer Action; (ii) the heavy litigation schedule of Sterling's trial counsel; and (iii) a medical emergency in the family of Sterling's manager, Phil Neuman, which prevented Sterling's counsel from consulting with Mr. Neuman about the motion until today, July 19, 2016, only three days before the current due date of July 22, 2016.

3. On July 19, 2016, counsel for the Plaintiff contacted counsel for the Defendants wherein they agree to extend the time to file an opposition to the Motion to Dismiss or Transfer Action by two weeks.

CONCLUSION

75. The due date for Sterling to respond to the Motion to Dismiss or Transfer [Doc# 12] should be extended by two weeks, from July 22, 2016 until August 5, 2016. A proposed Order is annexed as Exhibit A.

Dated this 21 day of July, 2016.

AVRAMSKI LAW, PC

/s/ Boris Avramski

Boris Avramski, Esq.

Nevada Bar No. 11350

AVRAMSKI LAW, PC

4640 W. Charleston Blvd.

Las Vegas, NV 89102

Phone: (702) 685-3618

Fax: (702) 664-0555

bkhelpvegas@yahoo.com

Attorney for Plaintiff Of Counsel:
Edward Griffith, Esq.
THE GRIFFITH FIRM
45 Broadway, Suite 2200
New York, New York 10006
(212) 363-3784
(212) 363-3790 (fax)

CERTIFICATE OF SERVICE

I, Boris Avramski, Esq., hereby certify that on July 21, 2016, I served the foregoing UNOPPOSED MOTION TO EXTEND PLAINTIFF'S TIME TO RESPOND TO MOTION TO DISMISS by the following means to the persons listed below:

X ECF System to:

Richard T Cunningham
Richard Cunningham Law
Email: rick@rcunninghamlaw.com
Attorney for Defendants

I declare under penalty of perjury that the foregoing is true and correct.

Dates this 21 day of July, 2016.

/s/Boris Avramski

Boris Avramski, Esq. AVRAMSKI LAW, PC
Boris Avramski, Esq.
Nevada Bar No. 11350
602 South 10 Street
Las Vegas, NV 89101
Phone: (702) 522-1808
Fax: (702) 685-3625
bkhelpvegas@yahoo.com
Attorney for Plaintiff ORDER EXTENDING PLAINTIFF'S TIME TO RESPOND TO MOTION TO DISMISS UNTIL AUGUST 5, 2016

Upon the unopposed motion of plaintiff Lux Sterling Holdings, LLC ("Sterling") to extend by two weeks the due date for its response to the Motion to Dismiss or Transfer Action [Doc# 12] filed by defendants Philip Whelan, Anthony Manerbino, Dawna Manerbino, and CNW, LLC (the "Moving Defendants"); and in light of the Moving Defendants' consent to the motion; and for good shown, it is

HEREBY ORDERED that the due date for Sterling's response to the Motion to Dismiss or Transfer Action [Doc# 12] is hereby extended by two weeks from July 22, 2016, to August 5, 2016.

Dated this 27th day of July, 2016

/s/_________

Hon. Richard F. Boulware, II,

District Court Judge