Opinion
2:22-cv-00762-RFB-DJA
08-09-2022
KIRSTEN A. MILTON LYNNE K. MCCHRYSTAL JACKSON LEWIS P.C.
KIRSTEN A. MILTON
LYNNE K. MCCHRYSTAL
JACKSON LEWIS P.C.
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO PLAINTIFF'S COMPLAINT
(FIRST REQUEST)
DANIEL J. ALBREGTS, UNITED STATES MAGISTRATE JUDGE
IT IS HEREBY STIPULATED by and between Plaintiff Brittany Hill (“Plaintiff”), through her counsel, Jenny Foley, Esq., and Defendant Nevada Restaurant Services, Inc. (“Defendant”), through its counsel Jackson Lewis P.C., that: (1) Defendant shall have an extension up to and including August 22, 2022 in which to file its response to Plaintiff's Complaint (ECF No. 1); (2) the Parties shall have an extension in which to file a report in compliance with Fed.R.Civ.P. 26(f) (“FRCP 26(f)”) up to and including September 22, 2022; and (3) the Parties shall have an extension of time to exchange their initial disclosures up to and including September 22, 2022. This Stipulation is submitted and based upon the following:
1. Defendant's response to the Complaint (ECF No. 1) is currently due on August 8, 2022.
2. The Parties respectfully request that the Defendant's deadline to file its response to the Complaint (ECF No. 1) be extended to August 22, 2022.
3. This is the first request for an extension of time for Defendant to file its response to Plaintiff's Complaint (ECF No. 1).
4. In addition, the current deadline to provide a report consistent with FRCP 26(f) and to exchange initial disclosures is September 8, 2022.
5. The Parties respectfully request that their deadline to file an FRCP 26(f) report and to exchange initial disclosures be extended to September 22, 2022.
6. This is the first request for an extension of time for the Parties to file the FRCP 26(f) report and to exchange initial disclosures.
7. This request is made in good faith and not for the purpose of delay.
8. Nothing in this Stipulation, nor the fact of entering to the same, shall have the effect of or be construed as waiving any claim or defense held by any party hereto.
ORDER
IT IS SO ORDERED: