Opinion
2:19-cv-00168-JAD-DJA
01-24-2022
KATHRYN MAYORGA, Plaintiff, v. CRISTIANO RONALDO, Defendant.
STOVALL & ASSOCIATES, LESLIE MARK STOVALL, ESQ., ROSS MOYNIHAN, ESQ., LARISSA DROHOBYCZER, Attorneys for Plaintiff Kathryn Mayorga. PETER S. CHRISTIANSEN, ESQ., KENDELEE L. WORKS, ESQ., KEELY A. PERDUE, ESQ., CHRISTIANSEN TRIAL LAWYERS, Attorneys for Defendant Cristiano Ronaldo.
STOVALL & ASSOCIATES, LESLIE MARK STOVALL, ESQ., ROSS MOYNIHAN, ESQ., LARISSA DROHOBYCZER, Attorneys for Plaintiff Kathryn Mayorga.
PETER S. CHRISTIANSEN, ESQ., KENDELEE L. WORKS, ESQ., KEELY A. PERDUE, ESQ., CHRISTIANSEN TRIAL LAWYERS, Attorneys for Defendant Cristiano Ronaldo.
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 [ECF 172] AND THE NEW YORK TIMES COMPANY'S MOTION TO INTERVENE [ECF 176] (SECOND REQUEST)
JENNIFER A. DORSEY U.S. DISTRICT JUDGE.
IT IS HEREBY STIPULATED AND AGREED BY AND BETWEEN Plaintiff KATHERINE MAYORGA by and through her attorney LESLIE MARK STOVALL, ESQ. and Defendant, CRISTIANO RONALDO, by and through his attorney PETER S. CHRISTIANSEN, ESQ., 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 18, 2022 be extended to January 25, 2022; and further that responses to The New York Times Company's Motion to Intervene [ECF 176], currently due on January 19, 2022, also be extended to January 25, 2022.
Plaintiffs counsel initially 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, because Plaintiffs counsel and his family tested positive and suffered the Covid-19 virus over the holidays which prevented Plaintiff from reviewing and completing plaintiffs response to the notice regarding real party in interest, Las Vegas Metropolitan Police Department, criminal investigative file [ECF 172] as well as responding to the New York Times Company's Motion to Intervene [ECF 176].
Defendant's Counsel 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 asserted good cause for the first one-week extension of the response deadlines.
Since the time this Court granted the parties first request for extension [ECF 179] making the foregoing responses due on January 18 and January 19, 2022, respectively, the Parties have been diligently working on their responses. However, Defendant's Counsel recently initiated negotiations in an attempt to resolve and/or further narrow the issues raised in the aforementioned briefs and responses. Good cause exists to extend the instant deadline for one additional week, in order to allow the Parties a more meaningful opportunity to exchange draft stipulations to explore such a resolution and accordingly, the Parties stipulate to the same.
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 18, 2022, be extended to January 25, 2022; and further that the parties' responses to The New York Times Company's Motion to Intervene [ECF 176], currently due on January 19, 2022, be extended to January 25, 2022.