Opinion
2:21-cv-00639-JCM-BNW
04-18-2022
JULIE HANNA, Plaintiff, v. K-KEL, INC.. a Nevada Corporation; DOES IX; ROE Business Entities I-X; Mark Broadhurst; Mike York; and Chase Swanson, Defendants.
Gary M. Gilbert, Esq. Pro Hac Vice Attorney for Plaintiff Allison Kheel, Esq. Attorney for Defendants
Gary M. Gilbert, Esq. Pro Hac Vice Attorney for Plaintiff
Allison Kheel, Esq. Attorney for Defendants
STIPULATION AND ORDER TO EXTEND DEADLINE FOR RESPONSE AND REPLY TO DEFENDANTS MARK BROADHURST'S AND CHASE SWANSON'S MOTIONS TO DISMISS (ECF NO. 60 + 61)
Pursuant to Local Rule 6-1, Defendant K-Kel, Inc. (“Defendant”) and Plaintiff Julie Danou Hanna (“Plaintiff”), by and through their undersigned counsel, hereby stipulate to a four (4) week extension of Plaintiff s deadline to file an Opposition to Defendants Mark Broadhurst's and Chase Swanson's Motions to Dismiss (ECF No. 60 + 61) and of Defendants' deadline to file a Reply to Plaintiff s Opposition, as follows:
| - | Old Deadline | New Deadline |
| Plaintiff s Opposition Deadline | April 18, 2022 | May 16, 2022 |
| Defendant's Reply Deadline | May 2, 2022 | May 30, 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 Oppositions to the Motions to Dismiss filed by Defendants Broadhurst and Swanson. 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.