Opinion
2:22-cv-00729-JCM-NJK
10-05-2022
Marguerite Brathwaite M.D., an individual Plaintiff's v. SOUTHWEST MEDICAL ASSOCIATES, INC., an active Nevada domestic Corporation; DOES 1-10 and ROE ENTITIES 1-10, inclusive. Defendants.
STIPULATION TO EXTEND DEADLINE FOR PLAINTIFF TO RESPOND TO DEFENDANT'S PARTIAL MOTION TO DISMISS [ECF No. 14]
(FIRST REQUEST)
IT IS HEREBY STIPULATED by and between Plaintiff Marguerite Brathwaite, M.D. (Plaintiff), through her counsel F. TRAVIS BUCHANAN, ESQ., of the law firm F. TRAVIS BUCHANAN & ASSOCIATES, PLLC., and Southwest Medical Associates, Inc. (“Defendant”), through its counsel JACKSON LEWIS P.C., that Plaintiff shall have an extension, up to and including Wednesday, October 26, 2022, in which to file an Opposition to Defendant's Partial Motion to Dismiss (ECF No. 14). This Stipulation is submitted and based upon the following:
1. Plaintiff's response to the Partial Motion to Dismiss (ECF No. 14) is currently due on October 5, 2022.
2. Due to Plaintiff's counsel being out of the country on pre-planned travel after i Defendant filed its Partial Motion to Dismiss (ECF No. 14), and the due date for a r Opposition falling 14 days thereafter, wherein Plaintiffs counsel was en route back t c the States from pre-planned international travel. Plaintiffs counsel needs additional tim t to conduct research, draft an Opposition to Defendant's Partial Motion to Dismiss, and file such Opposition to Defendant's Motion to Dismiss.
3. This is the first request for an extension of time for Plaintiff to file a response to Defendant's Partial Motion to Dismiss.
4. As a courtesy to Defendant, Plaintiff's counsel previously stipulated to two requests for an extension of time for Defendant to file a response to Plaintiff s Complaint, which the Court granted.
5. This request is made in good faith and not for the purpose of delay.
6. Nothing in this Stipulation, nor the fact of entering the same, shall have the effect of or be construed as waiving any claim or defense held by any party hereto.
ORDER
IT IS SO ORDERED: