Opinion
3:22-cv-00249-MMD-CLB
08-01-2023
CIRILO UCHARIMA ALVARADO, On Behalf of Himself and All Others Similarly Situated, Plaintiff, v. WESTERN RANGE ASSOCIATION, a California non-profit corporation; ELLISON RANCHING COMPANY, a Nevada corporation; JOHN ESPIL SHEEP CO., INC., a Nevada corporation; F.I.M. CORP., a Nevada corporation; THE LITTLE PARIS SHEEP COMPANY, LLC, a Nevada limited liability company; BORDA LAND & SHEEP COMPANY, LLC, a Nevada limited liability company; HOLLAND RANCH, LLC, a Nevada limited liability company; NEED MORE SHEEP CO., LLC, a Nevada limited liability company; and FAULKNER LAND AND LIVESTOCK COMPANY, INC., an Idaho corporation; Defendants.
Jerry Snyder Law Nevada State Bar No. 6830 429 Plumb Ln. Reno, Nevada 89509s Attorney for F.I.M. Corp, Inc Need More Sheep Co., LLC YAMAN SALAHI, ESQ (pro hac vice) Counsel for Plaintiff and Putative Class
Jerry Snyder Law Nevada State Bar No. 6830
429 Plumb Ln. Reno, Nevada 89509s
Attorney for F.I.M. Corp, Inc
Need More Sheep Co., LLC
YAMAN SALAHI, ESQ (pro hac vice)
Counsel for Plaintiff and Putative Class
STIPULATION AND ORDER (1) TO SET ASIDE ENTRY OF DEFAULT AGAINST FAULKNER LAND AND LIVESTOCK, COMPANY, INC., AND (2) TO EXTEND FAULKNER LAND AND LIVESTOCK'S TIME TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT (FIRST REQUEST)
Plaintiff CIRILO UCHARIMA ALVARADO (“Plaintiff'), by and through his counsel of record, YAMAN SALAHI, ESQ. of EDELSON, P.C. and Defendant FAULKNER LAND AND LIVESTOCK COMPANY, INC. (“Faulkner”), by and through its counsel of record, JERRY M. SNYDER of JERRY SNYDER LAW, hereby stipulate, and request this Court: (1) to set aside the default entered against Faulkner on July 18, 2023, and (2) to grant Faulkner leave to respond to the First Amended Complaint by August 10, 2023. Faulkner's response to Plaintiff's First Amended Complaint was due on July 12, 2023. Faulkner's long time attorney had recently retired, and while she stated that she would assist Faulkner in finding new counsel, she did not do so in a timely manner. Jerry Snyder, a sole practitioner, was not engaged until default had already been entered. Given the complexity of the issues involved, the procedural history of the case, and counsel's case load, more time is required to frame a response to the Complaint. The undersigned parties stipulate and request that this Court set aside the default and allow Faulkner to file its response to the First Amended Complaint by August 10, 2023. This stipulation does not affect the deadlines that are currently in place for Defendants that are not a party to this stipulation.
ORDER
IT IS SO ORDERED