Opinion
2:22-cv-01706 -APG-DJA
10-12-2022
JAY GELIZON, individually and on behalf of all others similarly situated, Plaintiff, v. SAMSUNG ELECTRONICS AMERICA, INC., Defendant.
KIND LAW MICHAEL KIND, ESQ. BRYAN PAUL THOMPSON, ESQ. (PRO HAC VICE TO BE SUBMITTED) ROBERT W. HARRER, ESQ. (PRO HAC VICE TO BE SUBMITTED) CHICAGO CONSUMER LAW CENTER, P.C. ATTORNEYS FOR PLAINTIFF JAY GELIZON AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED DICKINSON WRIGHT PLLC JOHN P. DESMOND JUSTIN J. BUSTOS JASON J. KIM (PRO HAC VICE TO BE FILED) HUNTON ANDREWS KURTH LLP ATTORNEYS FOR DEFENDANT SAMSUNG ELECTRONICS AMERICA, INC.
KIND LAW MICHAEL KIND, ESQ. BRYAN PAUL THOMPSON, ESQ. (PRO HAC VICE TO BE SUBMITTED) ROBERT W. HARRER, ESQ. (PRO HAC VICE TO BE SUBMITTED) CHICAGO CONSUMER LAW CENTER, P.C. ATTORNEYS FOR PLAINTIFF JAY GELIZON AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED
DICKINSON WRIGHT PLLC JOHN P. DESMOND JUSTIN J. BUSTOS JASON J. KIM (PRO HAC VICE TO BE FILED) HUNTON ANDREWS KURTH LLP ATTORNEYS FOR DEFENDANT SAMSUNG ELECTRONICS AMERICA, INC.
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT (FIRST REQUEST)
Defendant Samsung Electronics America, Inc. (“Samsung”) and Plaintiff Jay Gelizon (“Gelizon”), by and through their respective counsel of record, stipulate and agree as follows:
1. Plaintiff filed this lawsuit on September 2, 2022 against Samsung in the Eighth Judicial District Court, Clark County, Nevada, styled as Jay Gelizon v. Samsung Electronics America, Inc., Case No. A-22-857862-C, Department 3 (the “State Action”).
2. Plaintiff served a copy of the Complaint in the State Action on Samsung on September 14, 2022.
3. On October 10, 2022, Samsung removed the State Action to this Court (ECF No. 1).
4. Samsung's time to respond to the Complaint has not passed and runs until October 17, 2022. Fed.R.Civ.P. 81(c)(2)(C).
5. Samsung respectfully requests a forty-nine (49) day enlargement of time, up to and including December 5, 2022, in which to answer, move, or otherwise respond to the Complaint so that it may, among other things, gather information related to the allegations in the Complaint.
6. Plaintiff previously agreed to the same enlargement of time in the State Action, and, by this stipulation, reaffirms that agreement now that the case has been removed to this Court.
7. This stipulation is brought in good faith and not for the purpose of delay.
8. This is the first request filed in this Court for an extension of the deadline to respond to the Complaint.
ORDER
IT IS SO ORDERED.