Opinion
2:22-cv-00581
07-21-2023
CAA Industries, Ltd., Plaintiff, v. Recover Innovations, Inc. d/b/a Recover Tactical, Defendant.
SHLOMO S. SHERMAN, ESQ. Nevada Bar No. 009688 SHERMAN LAW, PLLC Kenneth M. Motolenich-Salas (AZ Bar No. 027499) Of Counsel to Weiss and Moy, P.C. MotoSalas Law, PLLC Attorneys for Defendant Recover Innovations, Inc. d/b/a Recover Tactical Sherman Law, PLLC Shlomo S. Sherman, Esq. Nevada Bar No. 009688 and Kenneth M. Motolenich-Salas (AZ Bar No. 027499 (pro hac vice) Of Counsel to Weiss and Moy, P.C. MotoSalas Law, PLLC Attorneys for Defendant Recover Innovations, Inc
SHLOMO S. SHERMAN, ESQ. Nevada Bar No. 009688 SHERMAN LAW, PLLC Kenneth M. Motolenich-Salas (AZ Bar No. 027499) Of Counsel to Weiss and Moy, P.C. MotoSalas Law, PLLC Attorneys for Defendant Recover Innovations, Inc. d/b/a Recover Tactical
Sherman Law, PLLC Shlomo S. Sherman, Esq. Nevada Bar No. 009688 and Kenneth M. Motolenich-Salas (AZ Bar No. 027499 (pro hac vice) Of Counsel to Weiss and Moy, P.C. MotoSalas Law, PLLC Attorneys for Defendant Recover Innovations, Inc
UNOPPOSED MOTION TO EXTEND DEADLINE FOR (I) PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION TO DISMISS AND (II) DEFENDANT TO REPLY TO DEFENDANT'S RESPONSE (FIRST REQUEST)
Defendant Recover Innovations, Inc. d/b/a Recover Tactical, by and through undersigned counsel and with no opposition from Plaintiff CAA Industries, Ltd., hereby respectfully requests that the Court grant Plaintiff an extension of one (1) week to respond to the pending Motion to Dismiss filed on July 7, 2023 (Doc. 54). Pursuant to LR IA 6-1, this is the first request for extension of time.
Currently, Plaintiff's response to the Motion to Dismiss is due July 21, 2023, with Defendant's reply due July 28, 2023. Defendant's counsel has a pre-planned, pre-paid family vacation planned nine months ago from July 23-30, 2023. To accommodate this, Defendant has requested that Plaintiff agree to a one-week extension of time for Plaintiff to respond to the Motion to Dismiss so that the reply due date does not fall during this brief vacation time. With such an extension, the response would be due July 28, 2023, and the reply due August 4, 2023. In email correspondence between the parties on July, 21, 2023, Plaintiff's counsel agreed to this proposal. This short request is sought in good faith and not pursued for undue delay. No further extensions will be sought.
For the foregoing reasons, Defendant respectfully requests the Court grant this Motion. Respectfully Submitted this 21st day of July, 2023.
IT IS SO ORDERED:
CERTIFICATE OF SERVICE
I hereby certify that I am an employee of MotoSalas Law, PLLC and that on the 21st day of July, 2023, pursuant to Fed.R.Civ.P. 5, LR 5-1 and LR IC 4-1, I caused to be served a true and correct copy of foregoing UNOPPOSED MOTION TO EXTEND DEADLINE FOR (I) PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION TO DISMISS AND (II) DEFENDANT TO REPLY TO DEFENDANT'S RESPONSE in the following manner:
(ELECTRONIC SERVICE) The above-referenced document was electronically served on the date hereof through the Notice of Electronic Filing automatically generated by the Court's facilities to those parties listed on the Court's Master Service List.