Opinion
2:23-cv-00402-JCM-DJA
04-05-2023
HELEN MOJTEHEDI, and individual Plaintff(s), v. CHRISTIAN DURANTE d/b/a and a/k/a DURANTE INSURANCE and FINANCIAL SERVICES also d/b/a and a/k/a DURANTE AGENCY; DOES 1 through 10 and ROE Corporations 11 through 20, Defendant(s).
Christian Gabroy Kaine Messer GABROY MESSER Attorneys for Plaintiff Jill Garcia Kelly B. Stout HONE LAW Attorneys flor Defendant
Christian Gabroy Kaine Messer GABROY MESSER Attorneys for Plaintiff
Jill Garcia Kelly B. Stout HONE LAW Attorneys flor Defendant
STIPULATION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF TO FILE RESPONSE TO DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT (First Request)
It is hereby stipulated by and between Plaintiff Helen Mojtehedi, (“Plaintiff”) through her counsel Christian Gabroy, Esq. and Kaine Messer, Esq. of Gabroy | Messer, and Defendant Christian Durante d/b/a and a/k/a Durante Insurance and Financial Services also d/b/a and a/k/a Durante Agency (“Defendant”) through its counsel Jill Garcia, Esq. and Kelly B. Stout, Esq. of Hone Law, shall have an extension up to and including April 18, 2023, for Plaintiff to file her response to Defendant's Motion to Dismiss (ECF No. 7). This is the first request for extension to file response to Defendant's Motion to Dismiss Plaintiff's Complaint. This stipulation is submitted per LR IA 6-1 and based upon the following:
1. The Plaintiff filed her Complaint on or about February 2, 2023, in the Eighth Judicial District Court.
2. Defendant removed this matter to the United States District Court on or about March 14, 2023.
3. Defendant filed his Motion to Dismiss Plaintiff's Complaint on or about March 21,2023.
4. Plaintiff's Response is currently due on or about April 4, 2022.
5. This is the first request for an extension of time for the Plaintiff to file her Response to Defendant's Motion to Dismiss Plaintiff's Complaint.
6. This request for extension is made in good faith, with good cause, and not for the purpose of delay but rather to conduct due diligence. Further, Plaintiff's counsel has prior scheduled travel commitments, needs to tend to personal family matters including matters relating to his father's medical prognosis, his ongoing legal matters, and requires the extension to conduct due diligence and potentially streamline various issues.
7. Nothing in this Stipulation, nor the fact of entering to the same, shall be construed as waiving any claim and/or defense held by any party.
IT IS SO STIPULATED.
Respectfully submitted, IT IS SO ORDERED