Opinion
2:23-cv-1568-JCM-BNW
10-27-2023
INK PROJECTS, LLC, Plaintiff, v. RUBEN KASPER, LLC, RUBEN ESTRELLADO, and MARVIN ESTRELLADO, Defendants.
KEMP JONES LLP MICHAEL J. GAYAN, ESQ., KATRINA STARK, ESQ., ATTORNEYS FOR DEFENDANTS AKERMAN LLP NATALIE L. WINSLOW, SBN 12125 ANDREW P. GOLD (PRO HAC PENDING) ATTORNEYS FOR PLAINTIFF
KEMP JONES LLP MICHAEL J. GAYAN, ESQ., KATRINA STARK, ESQ., ATTORNEYS FOR DEFENDANTS
AKERMAN LLP
NATALIE L. WINSLOW, SBN 12125
ANDREW P. GOLD (PRO HAC PENDING) ATTORNEYS FOR PLAINTIFF
STIPULATION AND ORDER TO EXTEND DEFENDANTS' TIME TO RESPOND TO PLAINTIFF'S AMENDED COMPLAINT (ECF NO. 2) AND TO OPPOSE PLAINTIFF'S VERIFIED MOTION FOR PRELMIINARY INJUNCTION AGAINST DEFENDANTS AND INCORPORATED MEMORANDUM OF POINTS AND AUTHORITIES (ECF NO. 9) (FIRST REQUEST)
BRENDA WEKSLER UNITED STATES JUDGE
Defendants RUBEN KASPER, LLC, RUBEN ESTRELLADO, and MARVIN ESTRELLADO (collectively, “Defendants”), by and through their counsel of record, Kemp Jones, LLP, and Plaintiff INK PROJECTS, LLC, by and through its counsel of record, Akerman LLP, hereby stipulate and agree as follows:
1. On October 2, 2023, Plaintiff commenced this case by filing its Complaint. ECF No. 1. Plaintiff subsequently filed its Amended Complaint the same day. ECF No. 2. On October 12, 2023, Plaintiff filed its Verified Motion for Preliminary Injunction Against Defendants and Incorporated Memorandum of Points and Authorities (“Motion for Preliminary Injunction”). ECF No. 9.
2. On October 5, 2023, Plaintiff served the Summons in a Civil Action and Amended Complaint on Defendants. ECF Nos. 6, 7, 8. Under FRCP 12, the current deadline for Defendants to respond to the Amended Complaint is October 26, 2023.
3. On October 12, 2023, Plaintiff served the Motion for Preliminary Injunction on Defendants by First Class Mail and Email. ECF Nos. 9, 15. Under LR 7-2(b), the current deadline for Defendants to oppose the Motion for Preliminary Injunction is October 26, 2023.
4. To provide Defendants and their recently retained counsel with sufficient time to review and respond to Plaintiff's allegations, Plaintiff and Defendants agree that Defendants shall have up to and including December 11, 2023, to respond to Plaintiff's Amended Complaint.
5. For similar reasons, the parties agree good cause exists to extend Defendants' deadline to oppose the Motion for Preliminary Injunction given Defendants' counsel only being recently retained, pre-existing professional obligations, and unexpected personal emergencies affecting Defendants' counsel.
6. Accordingly, the parties agree to extend Defendants' deadline to respond to the Motion for Preliminary Injunction by 21 days until November 16, 2023.
7. The stipulated extensions will not prejudice the parties' rights, nor will they impact other Court-imposed deadlines established in this case. This is the first request for a continuance of these briefing deadlines.
IT IS SO ORDERED