Opinion
2:22-cv-00511-GMN-DJA
04-20-2022
MARY PARRISH, Plaintiff, v. EVERI PAYMENTS, INC, and EVERI HOLDINGS, INC., Defendant.
David C. O'Mara (NV Bar No. 8599) THE O'MARA LAW FIRM, P.C. Frank S. Hedin HEDIN HALL LLP Counsel for Plaintiff MICHAEL N. FEDER, ESQ. (SBN 7332) KERRY E. KLEIMAN, ESQ. (SBN 14071) DICKINSON WRIGHT PLLC
David C. O'Mara (NV Bar No. 8599)
THE O'MARA LAW FIRM, P.C.
Frank S. Hedin
HEDIN HALL LLP
Counsel for Plaintiff
MICHAEL N. FEDER, ESQ. (SBN 7332)
KERRY E. KLEIMAN, ESQ. (SBN 14071)
DICKINSON WRIGHT PLLC
STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS' MOTION TO DISMISS
Gloria M. Navarro, District Judge
Pursuant to Local Rule IA 6-1, Plaintiff Mary Parrish (“Plaintiff”) and Defendants Every Payments, Inc. and Every Holdings, Inc. (“Defendants”) hereby stipulate to extend the time in which Plaintiff has to file her opposition to Defendants' motion to dismiss up to and including April 15, 2022. The parties respectfully ask this Court to enter an Order granting this extension and in support thereof state as follows:
1. Defendants filed a Petition for Removal on March 22, 2022. ECF 1.
2. Defendants filed a Motion to Dismiss on March 29, 2022. ECF 6. Plaintiff's opposition was due on April 12, 2022.
3. The Parties have met and conferred and stipulated that Plaintiff shall have up to and including, Friday, April 15, 2022, to file her opposition to the motion to dismiss. Defendants shall have 10 days, or up to and including April 25, 2022, to file their reply.
4. This is the first stipulation for extension of time for Plaintiff to oppose Defendants' motion to dismiss.
5. This request is made in good faith and not for the purpose of delay and the failure to file the opposition and this stipulation to extend time was based upon excusable neglect. Plaintiff's lead counsel had a family medical issue arise that impeded his ability to file a timely response.
ORDER
The deadline for Plaintiff to file her opposition to Defendants' motion to dismiss will be extended to and including Friday, April 15, 2022. Defendants shall have up to and including April 25, 2022 to file a reply thereto.
IT IS SO ORDERED nunc pro tunc.