Opinion
3:20-cv-00317-ART-CSD
04-24-2023
EUFEMIA GUILLEN, Plaintiff, v. B.J.C.R. L.L.C., a Nevada Limited Liability Company; B.J.H.S., LLC., a Nevada Limited Liability Company; R.C.S.J., LLC, a Nevada Limited Liability Company; Dhilan One L.L.C., a Nevada Limited Liability Company; CHAMPAK LAL, an Individual; and BHARAT B. LAL, an Individual, Defendants.
KEMP & KEMP, James P. Kemp, Esq. Attorney for Plaintiff. SIMONS HALL JOHNSTON PC, Anthony L. Hall, Esq., Sandra C. Ketner, Esq. Attorneys for Defendants.
KEMP & KEMP, James P. Kemp, Esq. Attorney for Plaintiff.
SIMONS HALL JOHNSTON PC, Anthony L. Hall, Esq., Sandra C. Ketner, Esq. Attorneys for Defendants.
ORDER APPROVING STIPULATION TO EXTEND TIME FOR PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT (ECF No. 81) AND FOR DEFENDANTS' REPLY
Anne R. Traum, United States District Court Judge.
Pursuant to LR IA 6-1 and LR 26-3, Defendants and Plaintiff Eufemia Guillen (“Plaintiff'), by and through their undersigned counsel, hereby stipulate to extend time for Plaintiff to Respond to Defendants' Motion for Summary Judgment (ECF No. 81) from the current deadline of April 21, 2023 through and including April 28, 2023 . Additionally, the Defendants will have an extension to May 19, 2023 to file their Reply. This is the second request for an extension of this specific deadline. The requested extension is sought in good faith and not for purposes of undue delay. The reasons for the extension are as follows:
1. Plaintiff's counsel, JAMES P. KEMP, ESQ., who is primarily working on the response to the summary judgment motion has been ill since the evening of Monday, April 17, 2023, with cold, flu, and allergy symptoms that appears to have caused conjunctivitis in his eyes that is limiting his ability to read or look at electronic screens for the extended periods of time necessary to address the extensive motion response briefing necessary. It is hoped that this will clear up by next week.
2. As result of the above unexpected illness, Plaintiff's counsel has not had time to address the summary judgment motion by the current deadline.
3. Additionally, counsel need to meet with Ms. Guillen to get her input in preparing the summary judgment response and will not be able to until Mr. Kemp meets with her on April 24th and/or 25th when he is scheduled to be in Elko for depositions in another matter. Counsel requires language interpretation assistance when speaking with Ms. Guillen and this is much more easily facilitated with in-person meetings.
4. Due to workload management needs associated with the Plaintiff's extension to April 28, 2023 to file a Response, the Defendants will have until May 19, 2023 to file a Reply.
Accordingly, additional time is needed and the parties request that the court grant this extension.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.