Opinion
3:22-cv-00084-MMD-CLB
08-08-2022
REBECCA BALLINGER, Plaintiff, v. PRIME HEALTHCARE SERVICES - RENO, LLC, a Foreign Limited Liability Company, dba St. Mary's Regional Medical Center. Defendant.
LITTLER MENDELSON Electronic Signature Authorized KARYN M. TAYLOR, ESQ., Attorneys for Defendant Prime Healthcare Services - Reno, LLC THE GEDDES LAW FIRM, P.C. WILLIAM J. GEDDES, ESQ. Attorney for Plaintiff Rebecca Ballinger
LITTLER MENDELSON
Electronic Signature Authorized
KARYN M. TAYLOR, ESQ.,
Attorneys for Defendant Prime
Healthcare Services - Reno, LLC
THE GEDDES LAW FIRM, P.C.
WILLIAM J. GEDDES, ESQ.
Attorney for Plaintiff Rebecca Ballinger
STIPULATION AND PROPOSED ORDER FOR ENLARGEMENT OF TIME
FOR PLAINTIFF TO FILE A REPLY BRIEF ON PLAINTIFF'S MOTION TO AMEND
(ECF 028)
(FIRST REQUEST)
The parties to this action, by and through their undersigned counsel of record hereby stipulate that Plaintiff may have a one (1)-week extension of time, through and including Friday, August 12, 2022 , to file her reply brief on her Motion to Amend (ECF 028). This is the first request for such an extension. The original deadline to file this opposition was Friday, August 5, 2022. The reason Plaintiff needs additional time to file this brief is because her counsel has a congested calendar and was out of the office on Friday, August 5, 2022, and he will need additional time to prepare a responsive brief.
This Stipulation is not offered for any dilatory or improper purpose.
CERTIFICATE OF SERVICE
I hereby certify that I am an employee of the Geddes Law Firm, P.C., and that on August 8, 2022 , I caused to be served a copy of the foregoing Stipulation and Proposed Order for Enlargement of Time for Plaintiff to File a Reply Brief on Plaintiff's Motion to Amend (ECF 028) (First Request), by electronic filing with the Court's Pacer e-filing system, addressed to: