Opinion
3:22-cv-00073-MMD-CLB
04-18-2022
JOHN P. EVPAK, an Individual, Plaintiffs, v. STATE OF NEVADA DEPARTMENT OF TAXATION, a political subdivision of the State of Nevada, Defendant.
STIPULATION, REQUEST, AND ORDER EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT
(SECOND REQUEST)
Defendant STATE OF NEVADA ex rel. its DEPARTMENT OF TAXATION (“Defendant” or “Taxation”) by and through its attorneys, AARON D. FORD, Attorney General for the State of Nevada, SCOTT H. HUSBANDS, Deputy Attorney General, pursuant to LR IA 6-1, LR IA 6-2, hereby submit their Stipulation, Request, and Order Extending Time to Answer or Otherwise Respond to Plaintiff's Complaint. This is the second request for an extension of time to file an answer or otherwise respond to Plaintiff's Complaint.
Plaintiff JOHN P. EVPAK (“Plaintiff” or “Mr. Evpak”), filed a Complaint (ECF No. 1) on February 7, 2022. Defendants were served the Complaint on February 16, 2022. The deadline for Defendants to answer or otherwise respond to the Complaint was March 8, 2022. Counsel met and conferred and agreed to extend that deadline to April 15, 2022. The Court approved that stipulation and entered an order approving the stipulation. (ECF No. 7). Taxation now seeks a second extension for that deadline based on a number of unexpected deliverables due in other matters. Counsel met and conferred electronically during the week of April 11 and are in agreement to extend the deadline for Taxation's responsive pleading to Friday, May 6, 2022. Pursuant to LR IA 6-1, the parties were unable to submit this form of Stipulation and Proposed Order prior to April 15, 2022 as a result of several planned absences from work and an inability to fully access the Court's electronic filing application.
Due to defense counsel's pre-existing professional obligations, and the complexity of Plaintiff's claims, Defendant needs additional time to prepare a responsive pleading or otherwise respond by motion to Plaintiff's Complaint.
Upon agreement by and between all the parties, through their respective counsel, the undersigned counsel request that this Court grant Defendant an extension of time, up to and including, May 6, 2022, to file an answer or otherwise respond by motion to Plaintiff's Complaint.
By entering into this stipulation, none of the parties waive any rights they have under statute, law, or rule with respect to Plaintiff's Complaint.
ORDER
IT IS SO ORDERED.