Opinion
CASE NO. 2:19-cv-01655-GMN-NJK
11-25-2020
DASHMESH ENTERPRISES, INC. A NEVADA CORPORATION D/B/A YOUR STOP, and RAVINDER S. GREWAL, an Individual, and RAJWANT K. GREWAL, an Individual Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.
Andrew Z. Tapp (FBN 68002) Pro Hac Vice METROPOLITAN LAW GROUP, PLLC 1971 W. Lumsden Road, #326 Brandon, Florida 33511-8820 Telephone: (813) 228-0658 Facsimile: (813) 330-3129 Email: andrew@metropolitan.legal And JOHN A. HUNT, ESQ. Nevada Bar No. 1888 CLARK HILL 3800 Howard Hughes Parkway Suite 500 Las Vegas, NV 89169 Telephone: (702) 862-8300 Facsimile: (702) 862-840 Email: jhunt@clarkhill.com COUNSEL FOR PLAINTIFFS
John A. Hunt
Nevada Bar No. 1888
CLARK HILL
3800 Howard Hughes Parkway
Suite 500
Las Vegas, NV 89169
702-862-83300
Email: jhunt@clarkhill.com Andrew Z. Tapp
Florida Bar No. 68002
Pro Hac Vice
METROPOLITAN LAW GROUP, PLLC
1971 W. Lumsden Road, #326
Brandon, Florida 33511-8820
813-228-0658
Email: Andrew@Metropolitan.Legal
PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
The Plaintiffs, DASHMESH ENTERPRISES, INC. a Nevada Corporation d/b/a YOUR STOP, RAVINDER S. GREWAL, an Individual, and RAJWANT K. GREWAL, an individual, by and through their undersigned counsel, and hereby respectfully move the Court for an enlargement of time to file its reply brief in opposition to Defendant's Motion For Summary Judgment filed on November 23, 2020 (Doc. 37), from December 14, 2020 up to and including January 4, 2021, and respectfully moves this Honorable Court for an entry of the attached proposed Order. CASE HISTORY & BACKGROUND
1. On November 23, 2020, Defendant's filed their Motion for Summary Judgment (Doc. 37).
2. Local Rule 7-2(b) provides that the Plaintiffs Response to the Defendant's Motion for Summary Judgment is due December 14, 2020.
3. Due to the undersigned's schedule and other pending deadlines in other judicial appeal matters Plaintiffs' counsel believes that such extension is necessary to complete the response to the Defendant's Motion for Summary Judgment.
4. The undersigned's office has conferred with the Defendant's counsel regarding this extension and was advised that the Defendant has no objection to the requested extension.
5. This is the Plaintiffs' first motion to extend time for filing their response in opposition to the Defendant's Motion for Summary Judgment.
6. As such, Plaintiffs request entry of an order granting them an extension up to and including January 4, 2021, an additional twenty-one (21) days, within which to file and serve their Response to the Defendant's Motion for Summary Judgment.
7. The Plaintiffs do not believe the requested extension will result in undue delay of this matter.
WHEREFORE, for the reasons set forth above, Plaintiffs, Dashmesh Enterprises, Inc., a Nevada Corporation d/b/a Your Stop, Ravinder S. Grewal, an Individual, Rajwant K. Grewal, an individual, respectfully request this Court enter an order granting the unopposed motion, and granting up to and including January 4, 2021 for the Plaintiffs' Response to the Defendant's Motion for Summary Judgment. Dated: November 25th, 2020
Respectfully submitted,
By: /s/ Andrew Z. Tapp
Andrew Z. Tapp (FBN 68002)
Pro Hac Vice
METROPOLITAN LAW GROUP, PLLC
1971 W. Lumsden Road, #326
Brandon, Florida 33511-8820
Telephone: (813) 228-0658
Facsimile: (813) 330-3129
Email: andrew@metropolitan.legal
And
JOHN A. HUNT, ESQ.
Nevada Bar No. 1888
CLARK HILL
3800 Howard Hughes Parkway
Suite 500
Las Vegas, NV 89169
Telephone: (702) 862-8300
Facsimile: (702) 862-840
Email: jhunt@clarkhill.com
COUNSEL FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 25, 2020, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following:
Patrick A. Rose, Esq.
Patrick.Rose@usdoj.gov
/s/ Andrew Z . Tapp
Andrew Z. Tapp (FBN 68002)
Pro Hac Vice John A. Hunt
Nevada Bar No. 1888
CLARK HILL
3800 Howard Hughes Parkway
Suite 500
Las Vegas, NV 89169
702-862-83300
Email: jhunt@clarkhill.com Andrew Z. Tapp
Florida Bar No. 68002
Pro Hac Vice
METROPOLITAN LAW GROUP, PLLC
1971 W. Lumsden Road, #326
Brandon, Florida 33511-8820
813-228-0658
Email: Andrew@Metropolitan.Legal
ORDER GRANTING PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
(Docket No. 38)
Pending before the Court is Plaintiffs' Unopposed Motion for Enlargement of Time to File Reply Brief in Opposition to Defendant's Motion for Summary Judgment. Docket No. 38. The Court having reviewed the unopposed motion therefore GRANTS the motion. Docket No. 38. The Plaintiffs, Dashmesh Enterprises, Inc., a Nevada Corporation d/b/a Your Stop, Ravinder S. Grewal, an Individual, and Rajwant K. Grewal, an individual may file their reply brief in opposition to Defendant's Motion for Summary Judgment on or before January 4, 2021.
IT IS SO ORDERED.
Dated this 1 day of December, 2020.
/s/_________
Gloria M. Navarro, District Judge
UNITED STATES DISTRICT COURT