Opinion
2:19-cv-0329-GMN-EJY
12-14-2022
NAVAJO HEALTH FOUNDATION - SAGE MEMORIAL HOSPITAL, INC. doing business as “Sage Memorial Hospital”; an Arizona non-profit corporation, Plaintiff, v. RAZAGHI DEVELOPMENT COMPANY, LLC; a Nevada limited liability company doing business as “Razaghi Healthcare”, AHMAD R. RAZAGHI; individually, TAUSIF HASAN; individually, DOES 1-10; Defendants.
KATHLEEN BLISS, ESQ. (NV Bar #7606) KATHLEEN BLISS LAW, PLLC -and- PAUL S. PADDA, ESQ. (NV Bar #10417) DAVID J. STANDER, ESQ. (Admitted PHV) PAUL PADDA LAW, PLLC and DOUGLASS A. MITCHELL, ESQ. (NV Bar #3775) JENNER & BLOCK, LLP Attorneys for Plaintiff
KATHLEEN BLISS, ESQ. (NV Bar #7606)
KATHLEEN BLISS LAW, PLLC
-and
PAUL S. PADDA, ESQ. (NV Bar #10417)
DAVID J. STANDER, ESQ. (Admitted PHV)
PAUL PADDA LAW, PLLC
and
DOUGLASS A. MITCHELL, ESQ. (NV Bar #3775)
JENNER & BLOCK, LLP
Attorneys for Plaintiff
JOINT STIPULATION TO EXTEND THIRD-PARTY DEFENDANTS' TIME TO RESPOND TO SECOND
AMENDED THIRD-PARTY CLAIMS (FIRST REQUEST)
Pursuant to Federal Rule of Civil Procedure (“FRCP”) 6 and the Court's Local Rule of Civil Practice 7-1, the parties hereby stipulate, subject to the Court's approval, to permit Third-Party Defendants Christi El-Meligi and Netrisha Dalgai additional time, to and until December 30, 2022, to respond to “Defendant RDC's Counterclaims And Second Amended Third-Party Claims” filed by Razaghi Development Company, LLC (“RDC”) on November 29, 2022. ECF No. 217.
In support of this Stipulation, the parties rely upon the following:
1. Undersigned counsel for Ms. El-Meligi and Ms. Dalgai (Paul Padda) is currently in trial which is not scheduled to conclude until December 15, 2022. Additionally, his co-counsel in this matter, are also very busy with competing case commitments during this same time-period. In light of the foregoing, respective counsel for the parties to this stipulation have communicated regarding this matter and agree that additional time is warranted under the circumstances.
2. Counsel for both parties respectfully request the Court approve this Stipulation and permit Ms. El-Meligi and Ms. Dalgai to respond to RDC's November 29, 2022 filing on or before December 30, 2022. . . .
The parties respectfully request the Court approve this Stipulation.
IT IS SO ORDERED.