Opinion
2:23-cv-01126-APG-DJA
08-03-2023
HOLLYWOOD CITIZEN NEWS OPERATING COMPANY, LLC, and HOLLYWOOD CITIZEN NEWS F&B, LLC, Plaintiffs, v. TEN FIVE HOSPITALITY LLC, and DAN DALEY, Defendants.
GARMAN TURNER GORDON LLP Dylan T. Ciciliano Nevada Bar No. 12348, KASOWITZ BENSON TORRES LLP Jennifer S. Recine (admitted pro hac vice), Donald J. Reinhard (admitted pro hac vice), Sean M. Sigillito (admitted pro hac vice) Attorneys for Plaintiffs SNELL & WILMER L.L.P. V.R. Bohman, Esq. Nevada Bar No. 13075 Erin M. Gettel, Esq. Nevada Bar No. 13877 SNELL & WILMER L.L.P. Attorneys for Defendants
GARMAN TURNER GORDON LLP Dylan T. Ciciliano Nevada Bar No. 12348, KASOWITZ BENSON TORRES LLP Jennifer S. Recine (admitted pro hac vice), Donald J. Reinhard (admitted pro hac vice), Sean M. Sigillito (admitted pro hac vice) Attorneys for Plaintiffs
SNELL & WILMER L.L.P. V.R. Bohman, Esq. Nevada Bar No. 13075 Erin M. Gettel, Esq. Nevada Bar No. 13877 SNELL & WILMER L.L.P. Attorneys for Defendants
STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFFS' COMPLAINT (ECF NO. 1) AND MOTION FOR PRELIMINARY INJUNCTION AND TO COMMENCE DISCOVERY (ECF NOS. 3 AND 4)
(FIRST REQUEST)
DANIEL J. ALBREGTS, UNITED STATES MAGISTRATE JUDGE
Plaintiffs Hollywood Citizen News Operating Company, LLC and Hollywood Citizen News F&B, LLC (collectively, “Plaintiffs”) and Defendants Ten Five Hospitality LLC and Dan Daley (collectively, “Defendants” and, together with Plaintiffs, the “Parties”), by and through their undersigned counsel, for good cause shown, hereby stipulate and agree that Defendants' counsel will accept service on behalf of Dan Daley, without prejudice to Mr. Daley's defenses or objections except under FRCP 12(b)(5), and to extend Defendants' deadline to file their response to Plaintiffs' Motion for Preliminary Injunction and Leave to Immediately Commence Discovery [ECF Nos. 3 and 4] (the “Motion”) from August 7, 2023, to August 18, 2023, to extend Defendants' deadline to answer, move, or otherwise respond to the Complaint [ECF No. 1] from August 14, 2023, to August 18, 2023, and to extend Plaintiff's reply deadline relative to the Motion to September 1, 2023, for the following reasons:
1. Plaintiffs served the Complaint and the Motion on July 24, 2023.
2. Defendants' response to the Motion is currently due on August 7, 2023.
3. Defendants' response to the Complaint is currently due on August 14, 2023.
4. Defendants' counsel has conflicting professional commitments and previously scheduled travel planned between July 24 and August 14, 2023, and the Complaint and Motion present complex and interrelated legal and factual issues warranting an extension of time for Defendants' responses.
5. Defendants are reviewing Plaintiffs' request for leave to immediately serve discovery (see ECF Nos. 3 and 4, at § IV), to determine whether this issue can be resolved by stipulation before Defendants' response date, and the Parties agree to meet and confer regarding the same.
6. This extension is sought in good faith and is not made for the purpose of delay.
THEREFORE, the Parties respectfully request an extension for Defendants to file their response to the Motion from August 7, 2023 to and including August 18, 2023, to file a response to the Complaint from August 14, 2023, to August 18, 2023, and of Plaintiffs' reply deadline relative to the Motion to September 1, 2023.
THE PARTIES SO STIPULATE
ORDER
IT IS SO ORDERED.