Opinion
2:19-cv-00168-JAD-DJA
01-12-2022
STIP LESLIE MARK STOVALL, ESQ. Nevada Bar No. 2566 ROSS MOYNIHAN, ESQ. Nevada Bar No. 11848 STOVALL & ASSOCIATES Attorney for Plaintiff PETER S. CHRISTIANSEN, ESQ. KENDELEE LEASCHER WORKS, ESQ. NICK D. CROSBY, ESQ. Nevada Bar No. 8996 JACKIE V. NICHOLS, ESQ. MARQUIS AURBACH COFFING
STIP
LESLIE MARK STOVALL, ESQ.
Nevada Bar No. 2566
ROSS MOYNIHAN, ESQ.
Nevada Bar No. 11848
STOVALL & ASSOCIATES
Attorney for Plaintiff
PETER S. CHRISTIANSEN, ESQ.
KENDELEE LEASCHER WORKS, ESQ.
NICK D. CROSBY, ESQ.
Nevada Bar No. 8996
JACKIE V. NICHOLS, ESQ.
MARQUIS AURBACH COFFING
STIPULATION TO EXTEND THE TIME FOR PLAINTIFF AND DEFENDANT'S RESPONSES TO THE NOTICE REGARDING REAL PARTY IN INTEREST'S. LAS VEGAS METROPOLITAN POLICE DEPARTMENT. CRIMINAL INVESTIGATIVE FILE TECF 1721 AND THE NEW YORK TIMES COMPANY'S MOTION TO INTERVENE TECF 1761
ECF, 178
IT IS HEREBY STIPULATED AND AGREED BY AND BETWEEN Plaintiff KATHERINE MAYORGA by and through her attorney LESLIE MARK STOVALL, ESQ. defendant, CRISTIANO RONALDO, by and through his attorney PETER S. CHRISTIANSEN, ESQ., and REAL PARTY IN INTEREST, LAS VEGAS METROPOLITAN POLICE DEPARTMENT by and through its attorneys NICK D. CROSBY, ESQ., and JACKIE V. NICHOLS; that the time for Plaintiff and Defendant's responses to the Notice Regarding Real Party In Interest's Las Vegas Metropolitan Police Department, criminal investigative file [ECF 172] currently due on January 11, 2022 be extended to January 18, 2022; and further that responses to The New York Times Company's Motion to Intervene [ECF 175], currently due on January 12, 2022, be extended to January 19, 2022.
Plaintiffs counsel requested a one-week extension of time for Plaintiff to file the foregoing responses. Defendant did not object and requested a reciprocal extension of time. Plaintiffs counsel was unable to complete drafting the subject responses on or before January 11, 2022, and January 12, 2022, respectively, for the following reasons:
Plaintiffs counsel and his family were tested positive and suffered Covid-19 virus over the holidays which prevent plaintiff from reviewing and completing plaintiffs response to the notice regarding real party in interest's, Las Vegas Metropolitan Police Department, criminal investigative file [ECF 172].
Defendant's Counsel has also had to dedicate substantial time to preparation for trial in other cases and has experienced staffing shortages associated with the recent uptick in COVID-19 cases. Accordingly, Defense Counsel likewise asserts good cause for a one-week extension of the response deadlines exists.
ORDER
IT IS HEREBY ORDERED that Plaintiff and Defendant's responses to the notice regarding real party in interest's, Las Vegas Metropolitan Police Department, criminal investigative file [ECF 172] currently due on January 11, 2022, be extended to January 18, 2022; and further that the parties' responses to The New York Times Company's Motion to Intervene [ECF 175], currently due on January 12, 2022, be extended to January 19, 2022.