Opinion
3:22-cv-00443-LRH-CSD
04-10-2023
B Diamond Infra LLC Plaintiff, v. CARMEN FERCH, AS TRUSTEE OF THE CARMEN FERCH TRUST, and the FEDERAL AVIATION ADMINISTRATION, Defendants.
JASON M. FRIERSON United States Attorney District of Nevada TROY K. FLAKE Assistant United States Attorney Attorneys for the United States HOLLAND & HART LLP Timothy A. Lukas Esq. Nevada Bar No. 4678 Joshua M. Halen, Esq. Attorney for Plaintiff JASON M. FRIERSON United States Attorney Troy K, Flake Assistant United States Attorney Attorney for the United States KAEMPFER CROWELL Richard G. Campbell, Jr., Esq. Attorney for Defendant Carmen Ferch as Trustee of the Carmen Ferch Trust
JASON M. FRIERSON United States Attorney District of Nevada TROY K. FLAKE Assistant United States Attorney Attorneys for the United States
HOLLAND & HART LLP Timothy A. Lukas Esq. Nevada Bar No. 4678 Joshua M. Halen, Esq. Attorney for Plaintiff
JASON M. FRIERSON United States Attorney Troy K, Flake Assistant United States Attorney Attorney for the United States
KAEMPFER CROWELL Richard G. Campbell, Jr., Esq. Attorney for Defendant Carmen Ferch as Trustee of the Carmen Ferch Trust
STIPULATION TO EXTEND THE UNITED STATES' DEADLINE TO ANSWER
(FOURTH REQUEST)
Pursuant to Local Rule IA 6-1, the parties stipulate and request that Defendants shall have a 30-day extension of time to file an answer or otherwise respond to Plaintiff's Complaint (ECF No. 1). The current deadline to answer is April 10, 2023. This is the Parties' fourth request for extension.
This matter involves a complex real property issue connected to an easement and a lease held by the Federal Aviation Administration for critical aviation communications infrastructure. The parties have worked diligently to verify important facts, discuss this matter with interested parties, and determine whether they can resolve this matter without litigation. They have circulated a draft stipulation that will resolve this matter which is being considered by the various parties.
One component of the resolution is a proposed negotiated lease between the Federal Aviation Administration (FAA) and B Diamond Infra. B Diamond has proposed lease terms which are being considered by the FAA and the parties are negotiating a draft lease. The parties continue to negotiate in good faith.
The parties agree that a 30-day extension of the 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 through and including May 10, 2023.
IT IS SO ORDERED: