Opinion
3:23-cv-00083-ART-CSD Civil Action 1:20-cv-04953 (S.D.N.Y.)
04-13-2023
STEPHEN BRAHMS, individually and on behalf of all others similarly situated, Movant, v. PAMELA KLESSIG, Respondent.
William E. Peterson (Bar No. 1538) Nathan G. Kanute (Bar No. 12413) SNELL & WILMER L.L.P. Attorneys for Respondent Patrick R. Leverty (NV Bar No. 8840) Leverty & Associates Law, Chtd. Andrea Farah (Pro hac vice) LOWEY DANNENBERG, P.C. Attorneys for Movant Stephen Brahms
William E. Peterson (Bar No. 1538)
Nathan G. Kanute (Bar No. 12413)
SNELL & WILMER L.L.P.
Attorneys for Respondent
Patrick R. Leverty (NV Bar No. 8840)
Leverty & Associates Law, Chtd.
Andrea Farah (Pro hac vice)
LOWEY DANNENBERG, P.C.
Attorneys for Movant Stephen Brahms
STIPULATION AND ORDER EXTENDING DEADLINE FOR RESPONSE TO MOTION TO COMPEL
(FIRST REQUEST)
Respondent, Pamela Klessig (“Respondent”), and Movant, Stephen Brahms (“Movant”, collectively with Respondent, the “Parties”) stipulate to extend the deadline for Respondent to respond to Movant's motion to compel through May 15, 2023. The Parties make the following stipulation for good cause, not for the purpose of delay, and for the following reasons:
1. Movant filed his Motion to Compel Non-Party Pamela Klessig's Compliance with Subpoena (the “Motion”) on February 27, 2023.
2. Respondent accepted service of the Motion on March 24, 2023.
3. Respondent served her responses and objections to Movant's subpoena of documents on April 7, 2023.
4. Movant's counsel is in the process of reviewing the responses and objections and the Parties have agreed to continue to discuss the potential resolution of the Motion.
5. The Parties need additional time to continue those discussions.
6. The response to the Motion is currently due on April 14, 2023.
7. The Parties have agreed to extend the time to file the response through May 15, 2023.
8. This stipulation is made in good faith and not for the purposes of delay.
Therefore, the Parties request that the Court grant the extension of the time to respond to the Motion through May 15, 2023.
ORDER
Good cause appearing, IT IS HEREBY ORDERED that the Parties' stipulation is GRANTED. The response to Movant's Motion to Compel Non-Party Pamela Klessig's Compliance with Subpoena shall be due on May 15, 2023.
IT IS SO ORDERED.