Opinion
2:23-cv-01126-APG-DJA
08-28-2023
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 KASOWITZ BENSON TORRES LLP Jennifer S. Recine (admittedpro hac vice) Donald J. Reinhard (admittedpro hac vice) Sean M. Sigillito (admitted pro hac vice) Attorneys for Plaintiffs Hollywood Citizen News Operating Company, LLC and Hollywood Citizen News F&B, LLC SNELL & WILMER L.L.P. V.R. Bohman, Esq. Nevada Bar No. 13075 Erin M. Gettel, Esq PRYOR CASHMAN LLP Todd E. Soloway (admitted pro hac vice) Dyan Finguerra-DuCharme (admitted pro hac vice)7 Times Square Attorneys for Defendants
GARMAN TURNER GORDON LLP Dylan T. Ciciliano KASOWITZ BENSON TORRES LLP Jennifer S. Recine (admittedpro hac vice) Donald J. Reinhard (admittedpro hac vice) Sean M. Sigillito (admitted pro hac vice) Attorneys for Plaintiffs Hollywood Citizen News Operating Company, LLC and Hollywood Citizen News F&B, LLC
SNELL & WILMER L.L.P. V.R. Bohman, Esq. Nevada Bar No. 13075 Erin M. Gettel, Esq PRYOR CASHMAN LLP Todd E. Soloway (admitted pro hac vice) Dyan Finguerra-DuCharme (admitted pro hac vice)7 Times Square Attorneys for Defendants
STIPULATION TO EXTEND DEADLINES FOR FILING OF OPPOSITION AND REPLY ON DEFENDANTS' MOTION TO STAY OR DISMISS PROCEEDINGS [ECF NOS. 26 AND 29] AND REPLY IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION AND LEAVE TO IMMEDIATELY COMMENCE DISCOVERY [ECF NOS. 3 AND 4] (SECOND REQUEST)
ANDREW P. GORDON UNITED STATES DISTRICT 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 to extend Plaintiffs' deadline to file their opposition to Defendants' Motion to Stay or Dismiss Proceedings [ECF Nos. 26 and 29] (the “Motion to Dismiss”) from September 1, 2023, to September 8, 2023, to extend Plaintiffs' deadline to file their reply in support of Plaintiffs Motion for Preliminary Injunction and Leave to Immediately Commence Discovery [ECF Nos. 3 and 4] (the “PI Motion”) from September 1, 2023, to September 8, 2023, and to extend Defendants' reply deadline relative to the Motion to Dismiss to September 22, 2023, for the following reasons:
1. Plaintiffs served the Complaint and the PI Motion on July 24, 2023.
2. The Parties previously requested an extension of Defendants' deadline to file their responsive pleading to the Complaint and their opposition to the PI Motion, which was granted by the Court on August 3, 2023. See ECF No. 18.
3. Defendants filed and served their Motion to Dismiss, and the Declaration and Exhibits in support thereof, on August 18, 2023.
4. Defendants filed and served their opposition to the PI Motion and the Declarations and Exhibits in support thereof, opposing the request for a preliminary injunction and the request for leave to immediately serve discovery, on August 18, 2023.
5. Plaintiffs' opposition to the Motion to Dismiss and reply in support of the PI Motion are both currently due on September 1, 2023.
6. The Motion to Dismiss and the PI Motion present complex and interrelated legal and factual issues concerning multiple disputes between the Parties, warranting an extension of time for Plaintiffs' opposition to the Motion to Dismiss and reply in support of the PI Motion.
7. The complexity of these legal and factual issues likewise warrants a one-week extension of time for Defendants' reply in further support of their Motion to Dismiss.
8. These extensions are sought and agreed to in good faith and are not made for the purpose of delay.
9. THEREFORE, the Parties respectfully request an extension of the deadline for Plaintiffs to file their opposition to the Motion to Dismiss from September 1, 2023 to and including September 8, 2023, for Plaintiffs to file their reply in support of the PI Motion from September 1, 2023 to and including September 8, 2023, and of Defendants' reply deadline relative to the Motion to Dismiss to September 22, 2023.
THE PARTIES SO STIPULATE
Dated this 25th August 2023.
ORDER
IT IS SO ORDERED.