Opinion
3:21-cv-00048-MMD-CLB
04-28-2023
ENVTECH, INC., a Nevada Corporation, Plaintiff, v. RICHARD VICTOR RUTHERFORD, an individual, Defendant.
SIMONS HALL JOHNSTON PC Anthony L. Hall Sandra Ketner Sierra Rose Drive Attorneys for Plaintiff. OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Anthony L. Martin Noel M. Hernandez Molly M. Rezac Attorneys for Defendant.
SIMONS HALL JOHNSTON PC Anthony L. Hall Sandra Ketner Sierra Rose Drive Attorneys for Plaintiff.
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Anthony L. Martin Noel M. Hernandez Molly M. Rezac Attorneys for Defendant.
STIPULATION AND ORDER TO EXTEND DEADLINE FOR FILING RESPONSES TO DISPOSITIVE MOTIONS [THIRD REQUEST]
Plaintiff EnvTech, Inc. (“Plaintiff” or “EnvTech”) and Defendant Richard V. Rutherford (“Defendant” or “Rutherford”) (collectively “the Parties”), by and through their respective counsel, hereby stipulate and agree that the deadlines for filing responses and replies to the Parties' pending dispositive motions be extended by one (1) day for the reasons set forth below.
The current deadline for filing responses to the Parties' pending dispositive motions is April 28, 2023 (ECF No. 82). However, Plaintiff's counsel's office is extremely short-staffed and the filing of Plaintiff's Opposition to Defendant's Motion for Summary Judgment requires significant administrative attention (including the filing of documents under seal and ensuring publicly filed documents are properly redacted pursuant to the Parties' Confidentiality Agreement and Stipulation for Entry of a Qualified Protective Order (ECF No. 25)). Therefore, the Parties request an additional one (1) day to submit their respective opposition motions and their corresponding replies. As a result, the parties have agreed to extend the deadline for filing responses to the pending dispositive motions by a period of one (1) business day (from Friday, April 28, 2023, to Monday, May 1, 2023) and have further agreed that their respective replies will be due on Monday, May 15, 2023).
The Parties have each filed dispositive motions. This is the third request specifically seeking extensions of the deadlines for responses and replies to dispositive motions. This request is made in good faith, is not for the purpose of delay. Accordingly, the Parties have agreed and stipulate to the following deadlines for the dispositive motions in this case:
1. Responses to Dispositive Motions:
The Parties shall file responses to dispositive motions no later than Monday, May 1, 2023.
2. Replies in Support of Motions:
The Parties shall file replies in support of motions no later than Monday, May 15, 2023.
3. Pretrial Order:
The Joint Pretrial order shall be suspended until thirty (30) days after the ruling on the ispositive motions.
ORDER
IT IS SO ORDERED.
PROOF OF SERVICE VIA ELECTRONIC SERVICE
I, Kelly Lee, declare:
I am employed in the City of Reno, County of Washoe, State of Nevada by the law offices of Simons Hall Johnston PC. My business address is 690 Sierra Rose Drive, Reno, Nevada 89511. I am over the age of 18 years and not a party to this action.
On April 28, 2023, I served the foregoing STIPULATION AND ORDER TO EXTEND DEADLINE FOR FILING RESPONSES TO DISPOSITIVE MOTIONS [THIRD REQUEST] by causing the document to be served via electronic service, addressed to the following e-mail addresses:
Anthony L. Martin, Esq.
Noel M. Hernandez, Esq.
Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
10801 West Charleston Boulevard, Suite 500
Las Vegas, NV 89135 702-369-6800 702-369-6888 (fax)
anthony.martin@ogletreedeakins.com noel .hernandez@ogletreedeakins .com
Molly Malone Rezac
Ogletree, Deakins, Nash, Smoak, & Stewart, P.C.
200 S. Virginia Street, 8th Floor
Reno, NV 89501
(775) 440-2372
(775) 440-2376 (fax)
molly.rezac@ogletreedeakins.com
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this declaration was executed on April 28, 2023.