Opinion
2:21-cv-00377-APG-DJA
08-01-2022
ERIN ALLEN, an Individual, Plaintiff, v. VOCATUS, LLC, a Nevada Limited Liability Company; SHAMOUN'S, LLC, a Nevada Limited Liability Company, DOES 1-50, inclusive and ROE CORPORATIONS 1-50, inclusive, Defendant.
JENNY L. FOLEY, Ph.D., ESQ. SARA SCHREIBER, ESQ. MICHAEL ARATA, ESQ. HKM EMPLOYMENT ATTORNEYS LLP Attorneys for Plaintiff OGLETREE, DEAKINS, NASH, SMOAK &STEWART, P.C. Suzanne L. Martin SUZANNE L. MARTIN, ESQ. MICHELLE C. KRAKORA, ESQ Attorneys for Defendants Vocatus, LLC and Shamoun's, LLC
JENNY L. FOLEY, Ph.D., ESQ. SARA SCHREIBER, ESQ. MICHAEL ARATA, ESQ. HKM EMPLOYMENT ATTORNEYS LLP Attorneys for Plaintiff
OGLETREE, DEAKINS, NASH, SMOAK &STEWART, P.C. Suzanne L. Martin SUZANNE L. MARTIN, ESQ. MICHELLE C. KRAKORA, ESQ Attorneys for Defendants Vocatus, LLC and Shamoun's, LLC
STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF ERIN ALLEN TO FILE RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
Plaintiff Erin Allen (“Allen”), and Defendants Vocatus, LLC and Shamoun's, LLC (together “Defendants”), by and through their respective attorneys of record, stipulate as follows:
1. On May 4, 2022, Defendants filed their Motion for Summary Judgment. [ECF No. 35].
2. On May 25, 2022, Plaintiff, through her prior counsel, filed a Motion to Extend Time to Respond to Motion for Summary Judgment [ECF No. 36], to which Defendants responded the same day. [ECF No. 37].
3. On May 31, 2022, Plaintiff's prior counsel, Trevor Hatfield, Esq., moved to withdraw as counsel for Plaintiff. [ECF No. 38].
4. On June 2, 2022, Defendants filed their response to the motion to withdraw. [ECF No. 40].
5. On June 3, 2022, this Court denied Mr. Hatfield's motion to withdraw as Plaintiff's counsel without prejudice and permitted Mr. Hatfield until June 17, 2022, to file a corrected motion to withdraw. [ECF No. 41].
6. On June 16, 2022, Mr. Hatfield filed a renewed motion to withdraw as counsel for Plaintiff. [ECF No. 42].
7. Defendants filed their notice of non-opposition to the motion to withdraw on June 20, 2022. [ECF No. 43].
8. On June 28, 2022, this Court granted Plaintiff's prior counsel's motion to withdraw and ordered that Plaintiff: (1) shall have until July 13, 2022, to retain new counsel or inform the Court whether she will proceed pro se; and (2) shall have until August 3, 2022, to respond to Defendants' Motion for Summary Judgment. [ECF No. 44].
9. On July 18, 2022, Plaintiff's new counsel of record, HKM Employment Attorneys LLP, appeared on Plaintiff's behalf. [ECF No. 45].
10. On July 28, 2022, Plaintiff's new counsel, HKM Employment Attorneys LLP, received Plaintiff's file from her prior counsel.
11. The parties hereby stipulate and agree Plaintiff shall have fourteen (14) additional days to file her response to Defendants' Motion for Summary Judgment. The new deadline for Plaintiff to file her response shall be August 17, 2022.
12. This is the second request for an extension of this deadline and is not made for purposes of undue delay.
IT IS SO ORDERED