Opinion
2:22-cv-00964-GMN-DJA
08-29-2022
CLARK COUNTY EDUCATION ASSOCIATION, Plaintiff, ALEXANDER ROCHE, an individual; Defendant. ALEXANDER ROCHE, Counter Claimant v. CLARK COUNTY EDUCATION; ASSOCIATION, a labor union and employer; CLARK COUNTY STAFF ORGANIZATION, a labor union; DOE BUSINESS ENTITIES 1-10; JOHN VELLARDITA, Executive Director of CCEA, an individual, in his individual and official capacities, Counter Defendants.
LAW OFFICE OF DANIEL MARKS Adam Levine, Esq. Robert S. Melcic, Esq. Attorneys for Counter-Defendants Clark County Education Association, Clark County Staff Organization and John Vellardita ROBERT S. MELCIC, ESQ. Attorney for Defendant/Counter-Claimant Alexander Roche
LAW OFFICE OF DANIEL MARKS
Adam Levine, Esq.
Robert S. Melcic, Esq.
Attorneys for Counter-Defendants
Clark County Education Association, Clark
County Staff Organization and John Vellardita
ROBERT S. MELCIC, ESQ.
Attorney for Defendant/Counter-Claimant
Alexander Roche
STIPULATION FOR EXTENSION OF TIME TO REPLY TO COUNTER-CLAIMANT'S OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANTS' SPECIAL MOTION TO DISMISS AND MOTION TO DISMISS
GLORIA M. NAVARRO, DISTRICT JUDGE
Plaintiff/Counter-Defendants CLARK COUNTY EDUCATION, ASSOCIATION (“CCEA”), CLARK COUNTY STAFF ORGANIZATION (“CCSO”), and JOHN VELLARDITA “(Vellardita”) (Collectively referred to herein as “Counter-Defendants”) by and through their attorneys of record, Adam Levine, Esq. and Daniel Marks, Esq. of the Law Office of Daniel Marks and Defendant/Counter-Claimant, ALEXANDER ROCHE (“Roche”) by and through his counsel, ROBERT S. MELICIC, ESQ., hereby stipulate to an extension of time for Counter-Defendants to file a reply to Defendant/Counter-Claimant's Opposition to Counter-Defendants' Special Motion to Dismiss and Motion to Dismiss (the “Motions”).
The parties have agreed to a two-week extension for Counter-Defendants to reply to the opposition to the Motions which are otherwise due on August 29, 2022.
The parties have met and conferred and agree that neither side will suffer prejudice from this Stipulation for Extension of Time. This request is not made to delay the proceedings. Instead, the request is made to accommodate the occurrence of unexpected and significant competing professional obligations of Counter-Defendants' counsel. In addition, Counter-Defendants' counsel needs this time to prepare for a major labor arbitration which is going forward on August 31, 2022, and he also has a number of briefs and responses on extension that are due at or about the time that the reply would otherwise be due.
Therefore, the parties respectfully request that Counter-Defendants' deadline to reply to the Motions be extended two weeks from August 29, 2022 to September 12, 2022.
IT IS SO ORDERED.