Opinion
2:19-CV-00985-CDS-NJK
10-10-2023
BRIAN BORENSTEIN, an individual, Plaintiff, v. THE ANIMAL FOUNDATION, a domestic nonprofit corporation; COUNTY OF CLARK, a political subdivision of the State of Nevada; SUNRISE HOSPITAL AND MEDICAL CENTER, LLC, a foreign limited-liability company domiciled in Delaware; CARLY SCHOLTEN, an individual; VICTOR ZAVALA, an individual; and ROE BUSINESS ENTITIES 1-5; and DOE INDIVIDUALS 1-5, Defendants,
THEPALMERLA WFIRM, P.C. Raelene Palmer ESQ., Robert Melcic, ESQ., Richard E. Retamar, ESQ., Retamar & Millian, P.A. Attorney for Plaintiff, Brain Borenstein WILEY PETERSEN Jonathan, Blum EAQ., Attorney for Defendant, County of Clark, Victor Zavala
THEPALMERLA WFIRM, P.C. Raelene Palmer ESQ., Robert Melcic, ESQ., Richard E. Retamar, ESQ., Retamar & Millian, P.A. Attorney for Plaintiff, Brain Borenstein
WILEY PETERSEN Jonathan, Blum EAQ., Attorney for Defendant, County of Clark, Victor Zavala
STIPULATION AND ORDER FOR DEFENDANTS' COUNTY OF CLARK AND VICTOR ZAVALA TO REPLY TO [ECF NO. 378] PLAINTIFF'S OPPOSITION TO MOTION TO DISMISS THIRD AMENDED COMPLAINT
[FIRST REQUEST]
Defendants, COUNTY OF CLARK (“Clark County”) and VICTOR ZAVALA (“Zavala”), by and through their counsel of record, Jonathan D. Blum, Esq., of the law firm Wiley Petersen and Plaintiff, BRIAN BORENSTEIN, by and through his counsel, Raelene K. Palmer, Esq. of The Palmer Law Firm, P.C., Robert S. Melcic, Esq. of The Law Office of Robert S. Melcic, and Richard E. Retamar, Esq. of Retamar & Millian, P.A., hereby stipulate and request the Court to extend the deadlines for Defendants Clark County and Zavala to reply to [ECF No. 378] Plaintiff's Opposition to [ECF No. 342], Motion to Dismiss Third Amended Complaint by Defendants County of Clark and Victor Zavala (the “Opposition”) from Thursday, October 12, 2023 to Friday, October 20, 2023.
This is the first request for an extension. The parties submit that this request is made in good faith and not for the purpose of undue delay. The Opposition is lengthy and raises numerous issues of fact and law, making six days to properly respond difficult. Additionally, counsel for Defendants Clark County and Lt. Zavala have several depositions, deadlines, and other time-sensitive work obligations from October 9 through October 12, necessitating an additional eight days to properly reply.
ORDER
IT IS SO ORDERED.