Opinion
2:21-cv-00639-JCM-BNW
04-18-2022
JULIE HANNA, Plaintiff, v. K-KEL, INC.. a Nevada Corporation; et al, Defendants. v.
Gary M. Gilbert, Esq. Pro Hac Vice Attorney for Plaintiff Mitchell Bisson, Esq. Nevada Bar No. 11920 Attorney for Defendant
Gary M. Gilbert, Esq. Pro Hac Vice Attorney for Plaintiff
Mitchell Bisson, Esq. Nevada Bar No. 11920 Attorney for Defendant
STIPULATION AND ORDER TO EXTEND DEADLINE FOR RESPONSE AND REPLY TO DEFENDANTS MICHAEL YORK MOTIONS TO DISMISS (ECF NO. 59) [THIRD REQUEST]|
Pursuant to Local Rule 6-1, Plaintiff Julie Danou Hanna (“Plaintiff”) and Defendant Michael York (“Defendant”), by and through their undersigned counsel, hereby stipulate to a four (4) week extension of Plaintiff's deadline to file an Opposition to Defendant Michael York's Motion to Dismiss (ECF No. 59) and Defendants' deadline to file a Reply to Plaintiff's Opposition, as follows:
Old Deadline
New Deadline
Plaintiff's Opposition Deadline
April 21, 2022
May 19, 2022
Defendant's Reply Deadline
April 28, 2022
May 26, 2022
This is the third request for an extension of these deadlines. The requested extension is sought in good faith and not for purposes of undue delay.
GOOD CAUSE FOR EXTENSION OF DEADLINES
This extension is necessitated by the withdrawal of Plaintiff s counsel Kathryn Black from this matter. Ms. Black was the lead attorney representing Plaintiff in the absence of Nicole Diaz, who is out on extended leave. Gilbert Employment Law P.C. is actively working to reassign Ms. Black's case duties and responsibilities, which include preparing Plaintiff s Opposition to the Motion to Dismiss filed by Defendant York. However, the firm is currently facing staffing shortages due to a number of employees being out on medical or other leave. A four-week extension would allow Plaintiff s counsel to reassign Ms. Black's responsibilities appropriately and with consideration for the staffing shortages as well as the heavy litigation schedule faced by the remainder of Plaintiff s counsel over the next few weeks.
ORDER
IT IS SO ORDERED.