Opinion
3:22-cv-00443-LRH-CSD
12-22-2022
B DIAMOND INFRA LLC, Plaintiffs, v. CARMEN FERCH, AS TRUSTEE OF THE CARMEN FERCH TRUST, and the FEDERAL AVIATION ADMNISTRATION, Defendants.
HOLLAND & HART LLP Timothy A. Lukas, Esq. Nevada Bar No. 4678 Joshua M. Halen, Esq. Attorney for Plaintiff KAEMPFER CROWELL Richard G. Campbell, Jr., Esq. Nevada Bar No. 1832 Attorney for Defendant Carmen Ferch as Trustee of the Carmen Ferch Trust JASON M. FRIERSON United States Attorney TROY K. FLAKE Assistant United States Attorney Attorney for the United States
HOLLAND & HART LLP Timothy A. Lukas, Esq. Nevada Bar No. 4678 Joshua M. Halen, Esq. Attorney for Plaintiff
KAEMPFER CROWELL Richard G. Campbell, Jr., Esq. Nevada Bar No. 1832 Attorney for Defendant Carmen Ferch as Trustee of the Carmen Ferch Trust
JASON M. FRIERSON United States Attorney
TROY K. FLAKE Assistant United States Attorney Attorney for the United States
STIPULATION TO EXTEND CARMEN FERCH, AS TRUSTEE OF THE CARMEN FERCH TRUST'S DEADLINE TO ANSWER [FIRST REQUEST]
Pursuant to Local Rule IA 6-1, the parties stipulate and request that Defendant Carmen Ferch, as Trustee of the Carmen Ferch Trust shall have a 30-day extension of time to file an answer or otherwise respond to Plaintiff's Complaint. (ECF No. 1). Based on the date of service of the summons and complaint on the Carmen Ferch, as Trustee of the Carmen Ferch Trust, the answer or other response is due by December 12, 2022. With the extension, the new deadline to answer or otherwise respond would be January 11, 2023. This is Carmen Ferch, as Trustee of the Carmen Ferch Trust's, first request for extension.
The parties are working diligently to verify important facts, discuss this matter with interested parties, and determine whether they can resolve this matter without litigation. The parties agree that a 30-day extension of the Carmen Ferch, as Trustee of the Carmen Ferch Trust's answer deadline is appropriate under the circumstances. This stipulation is filed in good faith and not for the purpose of delay.
WHEREFORE, the parties respectfully requests that this stipulation be granted and that the deadline to respond to the complaint be extended from December 12, 2022, through and including January 11, 2023.
IT IS SO ORDERED: