Opinion
2:23-cv-00032-RFB-EJY
02-22-2023
PAUL REIFFER, Plaintiff, v. WILD WEST HELICOPTERS INC., Defendant.
Lawrence J. Semenza, III, Esq., Bar No. 7174 Christopher D. Kircher, Esq., Bar No. 11176 Jarrod L. Rickard, Esq., Bar No. 10203 Katie L. Cannata, Esq., Bar No. 14848 SEMENZA KIRCHER RICKARD Attorneys for Defendant Wild West Helicopters Inc. RANDAZZA LEGAL GROUP, PLLC MARC J. RANDAZZA, ESQ. TREY A. ROTHELL, ESQ. Attorneys for Plaintiff Paul Reiffer
Lawrence J. Semenza, III, Esq., Bar No. 7174
Christopher D. Kircher, Esq., Bar No. 11176
Jarrod L. Rickard, Esq., Bar No. 10203
Katie L. Cannata, Esq., Bar No. 14848
SEMENZA KIRCHER RICKARD
Attorneys for Defendant Wild West Helicopters Inc.
RANDAZZA LEGAL GROUP, PLLC
MARC J. RANDAZZA, ESQ.
TREY A. ROTHELL, ESQ.
Attorneys for Plaintiff Paul Reiffer
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT BY 30 DAYS
[FIRST REQUEST]
This stipulation is entered into by Plaintiff Paul Reiffer ("Plaintiff"), by and through his counsel of record Trey A. Rothell, Esq., of Randazza Legal Group, PLLC, and Defendant Wild West Helicopters Inc. ("Defendant"), by and through its counsel of record Jarrod L. Rickard, Esq., of Semenza Kircher Rickard, with reference to the following facts and recitals:
1. Defendant was previously served with the Complaint filed by Plaintiff in this action;
2. On February 17, 2023, counsel for Defendant requested a 30-day extension of time to respond to the Complaint from counsel for Plaintiff;
3. Counsel for Defendant's request is based on the fact that he was just recently retained and requires time to get up to speed. Additionally, the Parties seek time to engage in settlement discussions and wish to avoid the unnecessary incurrence of attorney's fees and use judicial resources;
4. Based upon this request, the Parties have agreed to continue the deadline to respond to the Complaint to March 17, 2023; and
5. Defendant has not previously requested an extension of the deadline to answer, move or otherwise respond to the complaint.
NOW, THEREFORE, the parties hereby stipulate and agree, subject to Court approval, to extend the date by which Defendant is required to answer, move, or otherwise respond to the complaint to March 17, 2023.
Nothing in this stipulation shall be constructed as a waiver or relinquishment of any party's rights, remedies, objections, or defenses, all of which are expressly reserved.
IT IS SO ORDERED.