Opinion
2:22-cv-00628-GMN-VCF
10-16-2023
LAUREN L. LAVOIE, individually, LAUREN L. LAVOIE, as Guardian and Natural Parent of L.S., a Minor,; Plaintiffs, v. HYUNDAI MOTOR AMERICA, a Foreign Corporation; HYUNDAI MOTOR COMPANY, a Foreign Corporation; DOES I-X; ROES CORPORATIONS I-X; inclusive, Defendants.
CHRISTIANSEN TRIAL LAWYERS Peter S. Christiansen PETER S. CHRISTIANSEN, ESQ. Nevada Bar No. 5254 R. TODD TERRY, ESQ. Nevada Bar No. 6519 WHITNEY J. BARRETT, ESQ. Nevada Bar No. 13662 Attorneys for Plaintiffs BOWMAN AND BROOKE, LLP Lauren L. Walter PAUL G. CEREGHINI, ESQ. Nevada Bar No. 10000 LAUREN L. WALTER, ESQ. Nevada Bar No. 16464 MARIO D. VALENCIA, ESQ. Nevada Bar No. 6154 Attorneys for Defendants
CHRISTIANSEN TRIAL LAWYERS
Peter S. Christiansen
PETER S. CHRISTIANSEN, ESQ.
Nevada Bar No. 5254
R. TODD TERRY, ESQ.
Nevada Bar No. 6519
WHITNEY J. BARRETT, ESQ.
Nevada Bar No. 13662
Attorneys for Plaintiffs
BOWMAN AND BROOKE, LLP
Lauren L. Walter
PAUL G. CEREGHINI, ESQ.
Nevada Bar No. 10000
LAUREN L. WALTER, ESQ.
Nevada Bar No. 16464
MARIO D. VALENCIA, ESQ.
Nevada Bar No. 6154
Attorneys for Defendants
STIPULATION AND ORDER TO EXTEND PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTION TO DISMISS PLAINTIFFS' CLAIMS, OR ALTERNATIVELY, MOTION FOR SUMMARY JUDGMENT [ECF 41]
In accordance with this Defendants' Motion filed on September 29, 2023 (ECF No. 41), Plaintiffs Lauren L. Lavoie, individually and as Guardian and Natural Parent of L.S., a Minor (“Plaintiffs”), and Defendants Hyundai Motor America (“HMA”) and Hyundai Motor Company (“HMC”) (collectively, “Hyundai Defendants”), by and through their respective attorneys of record, hereby submit the present stipulation to respectfully request that the Court extend the October 13, 2023 deadline for Plaintiffs to respond to Hyundai's Motion to Dismiss Plaintiffs' Claims as a Spoliation Sanction, or Alternatively, Motion for Summary Judgment [ECF 41], filed on September 29, 2023, by one week to October 20, 2023.
1. The extension is due to work-load issues and unanticipated scheduling conflicts of Plaintiffs' current counsel, and in light of the crucial importance of the Hyundai Defendants' Motion and the cases dispositive sanctions sought therein, an extension of time is necessary to complete work on the motions. This is the first stipulation for the requested extension.
2. Although Plaintiffs' counsel has begun preparing and will continue to diligently work on Plaintiffs' response to the Hyundai Defendants' Motion, additional time is needed due to work-load related issues and unanticipated scheduling conflicts.
3. Thus, the parties stipulate and agree that the deadline for Plaintiffs to respond to the Hyundai Defendants' Motion to October 20, 2023. Additional time is not expected or needed.
4. This stipulation is made in good faith and not to delay the proceedings.
IT IS SO ORDERED.