Opinion
3:22-cv-00249-MMD-CLB
04-28-2023
THIERMAN BUCK LLP MARK R. THIERMAN, Nev. Bar No. 8285, JOSHUA D. BUCK, Nev. Bar No. 12187, LEAH L. JONES, Nev. Bar No. 13161, JOSHUA H. HENDRICKSON, Nev. Bar No. 12225, FAIRMARK PARTNERS, LLP JAMIE CROOKS, ESQ. (Pro Hac Vice) AISHA RICH, ESQ. (Pro Hac Vice), TOWARDS JUSTICE DAVID H. SELIGMAN, ESQ. (Pro Hac Vice) NATASHA VITERI, ESQ. (Pro Hac Vice) ALEXANDER HOOD, ESQ. (Pro Hac Vice), Attorneys for Plaintiff and the Putative Class. WOODBURN AND WEDGE, Ellen Jean Winograd, Esq. ELLEN JEAN WINOGRAD, Counsel for Defendant.
THIERMAN BUCK LLP MARK R. THIERMAN, Nev. Bar No. 8285, JOSHUA D. BUCK, Nev. Bar No. 12187, LEAH L. JONES, Nev. Bar No. 13161, JOSHUA H. HENDRICKSON, Nev. Bar No. 12225, FAIRMARK PARTNERS, LLP JAMIE CROOKS, ESQ. (Pro Hac Vice) AISHA RICH, ESQ. (Pro Hac Vice), TOWARDS JUSTICE DAVID H. SELIGMAN, ESQ. (Pro Hac Vice) NATASHA VITERI, ESQ. (Pro Hac Vice) ALEXANDER HOOD, ESQ. (Pro Hac Vice), Attorneys for Plaintiff and the Putative Class.
WOODBURN AND WEDGE, Ellen Jean Winograd, Esq. ELLEN JEAN WINOGRAD, Counsel for Defendant.
ORDER GRANTING STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE A FIRST AMENDED COMPLAINT AND FOR DEFENDANT TO RESPOND THERETO
Plaintiff CIRILO UCHARIMA ALVARADO (“Plaintiff”), by and through his counsel of record, AISHA RICH of FAIRMARK PARTNERS, LLP, and Defendant WESTERN RANGE ASSOCIATION (“Defendant”), by and through its counsel of record, ELLEN JEAN WINOGRAD of WOODBURN AND WEDGE, hereby stipulate, and request this Court, to (1) grant Plaintiff leave to file a First Amended Complaint by June 16, 2023 and (2) to grant Defendant leave to respond to the First Amended Complaint by July 17, 2023.
The Answer to Plaintiff's original Complaint is currently due May 19, 2023. Plaintiff has recently informed Defendant that he intends to file an Amended Complaint in order to obtain Defendant's consent as is required by Fed.R.Civ.P. 15(a)(2). The Parties conferred and have agreed on a proposed amended pleadings schedule, as follows:
• Plaintiff will file his First Amended Complaint by June 16, 2023; and
• Defendant will file its response by July 17, 2023.
Plaintiff and Defendant intend to have their Local Rule 26(f) conference on or before June 4, 2023, as previously specified by stipulation to this Court. See Dkt. 44. However, in light of the timing of Plaintiff's First Amended Complaint, the Parties further stipulate, and request this Court, to allow them to file their stipulated discovery plan and scheduling order by June 30, 2023, instead of within 14 days of the conference, as is required by Local Rule 26-1(a).
This Stipulation was prepared by counsel for Plaintiff with the consent of Defendant and is made in good faith and not for purposes of delay.
ORDER
IT IS SO ORDERED.