Opinion
3:22-cv-00451-ART-CSD
11-23-2022
REBECCA CARTWRIGHT, Plaintiff, v. WSCC, INC., dba SIERRA WELL, Defendant.
MARK MAUSERT LAW OFFICE Mark Mausert #2398 Sean McDowell #15962 Attorneys for Plaintiff Rebecca Cartwright KAMER ZUCKER ABBOTT Scott M. Abbott #4500 Jen J. Sarafina #9679 Attorneys for Defendant WSCC, Inc., dba Sierra Well
MARK MAUSERT LAW OFFICE Mark Mausert #2398 Sean McDowell #15962 Attorneys for Plaintiff Rebecca Cartwright
KAMER ZUCKER ABBOTT Scott M. Abbott #4500 Jen J. Sarafina #9679 Attorneys for Defendant WSCC, Inc., dba Sierra Well
STIPULATION AND REQUEST FOR EXTENSION OF TIME FOR DEFENDANT TO RESPOND TO COMPLAINT (FIRST REQUEST)
Plaintiff Rebecca Cartwright and Defendant WSCC, Inc., dba Sierra Well, by and through their respective counsel of record, hereby stipulate and request that the deadline for Defendant to answer or otherwise respond to the Complaint be extended from the present date of November 7, 2022 to January 10, 2023. In support of this Stipulation and Request, the parties state as follows:
1. Plaintiff served the Summons and Complaint on Defendant on October 17, 2022, rendering an answer or other initial appearance due by November 7, 2022.
2. The undersigned counsel was retained by Defendant on November 17, 2022, following Defendant's diligent search for representation. Defendant's counsel will need sufficient time to review this matter in order to prepare a proper response to the Complaint. Counsel for both Plaintiff and Defendant have conferred during the week of
November 14, 2022 regarding the need for an extension of time to respond to the Complaint, and they have agreed to an extension of time up to and including January 10, 2023.
3. This extension is requested for the reasons stated above and not for purposes of delay or any other improper purposes.
4. This is the first request for an extension of time in this matter.
IT IS SO ORDERED.