Opinion
3:22-cv-00479-LRH-CLB
11-22-2022
RORY L. BUCKNER, Plaintiff, v. UNION PACIFIC RAILROAD COMPANY, Defendant.
STEPHANIE L. QUINN (NV BAR NO. 12632) QUINN • COVARRUBIAS JEFFREY S. SPENCER (NV BAR NO. 9197) SILVER STATE LAW, LLC Attorneys for Defendant UNION PACIFIC RAILROAD COMPANY
STEPHANIE L. QUINN (NV BAR NO. 12632) QUINN • COVARRUBIAS JEFFREY S. SPENCER (NV BAR NO. 9197) SILVER STATE LAW, LLC Attorneys for Defendant UNION PACIFIC RAILROAD COMPANY
ORDER GRANTING DEFENDANT UNION PACIFIC RAILROAD COMPANY'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING (1st REQUEST)
Pursuant to Fed R. Civ. P. 6(b) and L.R. IA 6-1(a), Defendant Union Pacific Railroad Company (“UPRR”) moves to extend the deadline to file its response to Plaintiff's Complaint by two weeks, to December 9, 2022. In making its unopposed motion, UPRR expressly preserves all Rule 12 defenses.
This motion is made in good faith and not for any improper purpose. UPRR requests an extension of the time to respond to the Complaint to allow more time to meet and confer with Plaintiff's counsel regarding the contents of the Complaint and potential pleading deficiencies therein. UPRR's counsel began efforts to meet and confer on Friday, November 18, 2022, but due to scheduling conflicts and the Thanksgiving holiday, counsel do not anticipate completing their meet and confer until after UPRR's responsive pleading deadline, which is currently November 25, 2022. Counsel for Plaintiff has agreed to stipulate to a two-week extension to file a responsive pleading to allow the parties time to meet and confer regarding the contents of the Complaint. Filed herewith is a Declaration of Stephanie L. Quinn and attached as Exhibit 1 is correspondence with Plaintiff counsel regarding his agreement to stipulate to a continuance of the responsive pleading deadline for two-weeks.
Defendant UPRR respectfully requests that the Court grant this request for an extension of time to file a responsive pleading, to December 9, 2022.
ORDER
IT IS SO ORDERED.