Opinion
3:19-CV-00239-MMD-CLB
10-06-2022
MICHAEL J. FLYNN and PHILIP STILLMAN, Plaintiffs, v. MICHAEL E. LOVE, an individual; and JACQUELINE LOVE, an individual; MICHAEL E. LOVE as TRUSTEE OF THE MICHAEL LOVE FAMILY TRUST; MELECO, INC., a Nevada corporation; and DOES 1-10, Defendants. REBECCA FLYNN-WILLIAMS, AS SUCCESSOR TRUSTEE OF THE LAIMA FLYNN TRUST, Intervenor
MICHAEL J. FLYNN, ESQ. In Proper Person PHILIP STILLMAN, ESQ. In Proper Person ROBISON, SHARP, SULLIVAN & BRUST KENT R. ROBISON MICHAEL A. BURKE HANNAH E. WINSTON Attorneys for the Rebecca Flynn- Williams As Successor Trustee for the Laima Flynn Trust GREENBERG TRAURIG, LLP MARK E. FERRARIO, ESQ. JASON K. HICKS, ESQ. Attorneys for Defendants
MICHAEL J. FLYNN, ESQ. In Proper Person
PHILIP STILLMAN, ESQ. In Proper Person
ROBISON, SHARP, SULLIVAN & BRUST KENT R. ROBISON MICHAEL A. BURKE HANNAH E. WINSTON Attorneys for the Rebecca Flynn- Williams As Successor Trustee for the Laima Flynn Trust
GREENBERG TRAURIG, LLP MARK E. FERRARIO, ESQ. JASON K. HICKS, ESQ. Attorneys for Defendants
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO OPPOSE DEFENDANTS' MOTION FOR PARTIAL SUMMARY JUDGMENT (SECOND REQUEST)
Plaintiffs MICHAEL J. FLYNN (individually, "Flynn") and PHILIP STILLMAN ("Stillman"), in proper person (collectively, "Plaintiffs"), and Defendants MICHAEL E. LOVE, JACQUELINE LOVE, MICHAEL E. LOVE as Trustee of the Michael Love Family Trust, and MELECO, INC. (collectively, "Defendants"), through their attorneys of record, and Intervenor REBECCA FLYNN-WILLIAMS, AS SUCCESSOR TRUSTEE OF LAIMA FLYNN TRUST (the "Trust"), represented by Kent R. Robison, Esq., Michael A. Burke, Esq., and Hannah E. Winston, Esq., of the law offices Robison, Sharp, Sullivan & Brust, hereby stipulate to extend the time to file an opposition to Defendants' Motion for Partial Summary Judgment (ECF 265). The current deadline to file the opposition is October 5, 2022 pursuant to the First Request to extend the deadline to file the opposition (ECF 268). Plaintiffs and the Trust request an extension to file the opposition on or before October 7, 2022.
The Parties hereby agree that the above requested extension is made in good faith and not for the purpose of delay. The attorney taking the lead in drafting the joint opposition (Hannah E. Winston, Esq.) had a family emergency that unfortunately delayed finalizing the joint opposition by close of business on October 5, 2022. Notwithstanding, the opposition will be finalized and filed no later than October 7, 2022.
IT IS SO STIPULATED.
IT IS SO ORDERED.