Opinion
2:19-cv-00985-CDS-NJK
10-04-2023
BRIAN BORENSTEIN, an individual, Plaintiff, v. THE ANIMAL FOUNDATION, et al., Defendants.
THE LAW OFFICE OF ROBERT S. MELCIC ROBERT S. MELCIC, ESQ.
THE LAW OFFICE OF ROBERT S. MELCIC
ROBERT S. MELCIC, ESQ.
UNOPPOSED MOTION FOR EXTENSION OF TIME TO REPLY TO DEFENDANTS' OPPOSITIONS TO PLAINTIFF'S RENEWED MOTION TO REOPEN AND EXTEND DEPOSTION OF COUNTY'S RULE 30(B)(6) WITNESS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 30(D)(1) (FIRST REQUEST)
NANCY J. KOPPE, UNITED STATES MAGISTRATE JUDGE
COMES NOW Plaintiff, Brian Borenstein, by and through his counsel, Raelene K. Palmer, Esq. of The Palmer Law Firm, P.C., and Robert S. Melcic, Esq., and hereby moves unopposed for an enlargement of time to reply to Defendants' Oppositions [ECFs 369 and 370, respectively] to Plaintiff's Renewed Motion to Reopen and Extend Deposition of County's Rule 30(b)(6) Witness Pursuant to Federal Rule of Civil Procedure 30(d)(1). This Motion is brought with the following Memorandum of Points and Authorities, the papers and pleadings on file in this case, and any further briefing or oral argument this honorable Court may wish to entertain.
MEMORANDUM OF POINTS AND AUTHORITIES
I. INTRODUCTION
Plaintiff is seeking a six-day extension, until Monday, October 9, 2023, to reply to Defendants' Oppositions to Plaintiff's Renewed Motion to Reopen and Extend Deposition of County's Rule 30(b)(6) Witness Pursuant to Federal Rule of Civil Procedure 30(d)(1).
II. RELEVANT PROCEDURAL HISTORY
On September 12, 2023, Plaintiff filed his Motion to Take Deposition from Clark County Rule 30(b)(6) as renewed following ECF 359, Order on Motion to Take Deposition. Defendant Clark County opposed on September 26, 2023 [ECF 369] and Defendant The Animal Foundation opposed later that same day [ECF 370]. Defendants' Oppositions set an original deadline for Plaintiff to reply by October 3, 2023. However, due to additional work in this and in other cases, Plaintiff has been forced to seek an extension.
III. LEGAL ANALYSIS
Federal Rule of Civil Procedure 6(b)(1)(A) provides in pertinent part:
(b) EXTENDING TIME.
(1) In General. When an act may or must be done within a specified time the court may, for good cause, extend the time:
(A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires;
A. Plaintiff Has Good Cause for an Extension of Time.
Plaintiff needs additional time to reply and requests until Monday, October 9, 2023. Plaintiff has been working on his opposition to the most recent Motion to Dismiss in this case. Also, Plaintiff attended an all-day deposition in this case on October 2, 2023. That and other case matters have led to a situation in which Plaintiff needs an enlargement of time to reply. During the deposition on October 2, all parties agreed to this extension. Thus, this motion is unopposed.
IV. CONCLUSION
Based on the foregoing, Plaintiff respectfully requests the Court to grant him a six-day extension of time to reply to Defendants' Oppositions to Plaintiff's Renewed Motion to Reopen and Extend Deposition of County's Rule 30(b)(6) Witness Pursuant to Federal Rule of Civil Procedure 30(d)(1).
ORDER
IT IS SO ORDERED.