Opinion
2:21-cv-00464-CDS-VCF
02-02-2023
LAKISHA LEWIS, Plaintiff v. SUNRISE HOSPITAL AND MEDICAL CENTER, LLC, a Delaware Limited Liability Company; DOES I-X; and, ROE Business Entities I-X, Defendants
KEMP & KEMP, OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. James P. Kemp, Esq. Anthony L. Martin Noel M. Hernandez
KEMP & KEMP,
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
James P. Kemp, Esq.
Anthony L. Martin
Noel M. Hernandez
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
[SECOND REQUEST]
Pursuant to LR IA 6-1 and LR 26-3, Defendant Sunrise Hospital and Medical Center, LLC (“Defendant”) and Plaintiff LaKisha Lewis (“Plaintiff), by and through their undersigned counsel, hereby stipulate to extend time for Plaintiff to Respond to Defendants' Motion for Summary Judgment (ECF No. 33) from the current deadline of January 31, 2023 through and including February 7, 2023 . This is the second request for an extension of this specific deadline. The requested extension is sought in good faith and not for purposes of undue delay. The reasons for the extension are as follows:
1. Plaintiff's counsel continues to work with Ms. Lewis to get her input in preparing the summary judgment response and this is complicated by Ms. Lewis's being located in
North Carolina (necessitating working around time zone differences and her work schedule).
2. Plaintiff's counsel continues experiencing a very heavy workload. He filed an opening brief in a Ninth Circuit case (Raffele v. VCA, Inc.) on January 17; another summary judgment opposition in another case (Matthys vs. Barrick Turquoise Ridge, Inc.) on January 23, 2023; and another summary judgment opposition in another case (McIntosh vs. City of North Las Vegas) on January 30, 2023.
3. Additionally, Plaintiff's counsel has had multiple administrative workers' compensation hearings and appeals on January 17, 24, and 27, 2023.
4. Additionally, Plaintiff's counsel had two new clients come in with their 90 day right to sue notices from Nevada Equal Rights Commission and EEOC expiring on January 30, 2023 that had to be filed by the deadline.
5. Additionally, Plaintiff's counsel came down with an upper respiratory condition (not COVID-19) that he has been fighting for two weeks and is just now getting over.
6. The parties further stipulate that Defendant shall have a similar extension of the deadline to file its Reply to and including March 7, 2023 .
Accordingly, additional time is needed and an extension to February 7, 2023 for the Opposition is requested. Defendant will also have an extension of the deadline to file its Reply until March 7, 2023 .
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.