Opinion
No: 2:22-cv-01840-RFB-DJA
12-27-2022
Taylor N. Jorgensen LAGOMARSINO LAW Andre M. Lagomarsino, Esq. Taylor N. Jorgensen, Esq. Attorneys for Plaintiff Justyn Hornor Jacob L. Fonnesbeck SF FIRM, LLP Mark L. Smith, Esq. Jacob L. Fonnesbeck, Esq. Attorneys for Defendants Brandon Wey and Reflex Media, Inc.
Taylor N. Jorgensen LAGOMARSINO LAW Andre M. Lagomarsino, Esq. Taylor N. Jorgensen, Esq. Attorneys for Plaintiff Justyn Hornor
Jacob L. Fonnesbeck SF FIRM, LLP Mark L. Smith, Esq. Jacob L. Fonnesbeck, Esq. Attorneys for Defendants Brandon Wey and Reflex Media, Inc.
STIPULATION AND ORDER TO EXTEND THE DEADLINES FOR PLAINTIFF'S OPPOSITION TO AND DEFENDANTS' REPLY IN SUPPORT OF DEFENDANTS' MOTION TO DISMISS
RICHARD E. BOUL WARE II JUDGE United States District Court
Pursuant to LR 6-1, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend the deadline to file Plaintiff's Opposition to Defendants' Motion to Dismiss (ECF No. 12) in the above-captioned case for twenty-six (26) days, up to and including Monday, January 23, 2023.
The parties likewise agree to extend Defendants' deadline to file their subsequent Reply in Support of their Motion to Dismiss up to and including February 6, 2023.
This Request for an extension of time is not sought for any improper purpose or other purpose of delay. This request for extensions is based upon the following:
The Winter Holidays are quickly approaching, and both Plaintiff's and Defendants' counsel will have reduced availability;
Plaintiff's counsel is preparing for and conducting a full-day deposition on December 20, 2022;
Plaintiff's counsel is preparing for trial in the matter of Kennedy t al. v. Las Vegas Sands Crop. Et al. 2:17-cv-200880-APG-VCF and the Honorable Judge Gordon has instructed both Plaintiffs' and Defendants' counsel to give all the younger associate attorneys an active role in the trial;
Immediately following the trial, Plaintiff's counsel will be preparing for and conducting and all-day deposition of an expert witness on January 16, 2023.
Defendants' counsel will be occupied with depositions in another matter the week of and following the proposed February 6, 2023 deadline.
WHEREFORE, the parties respectfully request that this Court extend the time for Plaintiff to file his Opposition to Defendants' Motion to Dismiss (ECF No. 12) by twenty-six (26) days from the current deadline of December 28, 2022, up to and including January 23, 2023, and to extend the time for Defendants' to file their Reply in Support of their Motion to Dismiss up to and including February 6, 2023.
ORDER
IT IS SO ORDERED.