Opinion
2:22-CV-00635-VCF
04-28-2022
CARLOS ROBERTS, Plaintiff, v. UBER TECHNOLOGIES, INC., a foreign corporation, dba UBER; RASIER LLC, a foreign limited liability company, dba UBER; JAMES RIVER INSURANCE COMPANY; DOE CLAIM ADJUSTER I through X; DOE CLAIM SUPERVISOR I through X; ROE INSURANCE COMPANY XI through XX; DOES I through X, inclusive; ROE CORPORATION XI through XX, inclusive and ROE COMPANIES I-X, Defendants.
JANICE M. MICHAELS NICHOLAS F. ADAMS NEVADA BAR NO. 14813 WOOD SMITH HENNING & BERMAN ATTORNEYS FOR UBER TECHNOLOGIES, INC. AND RASIER, LLC ERRONEOUSLY SUED AS UBER TECHNOLOGIES, INC. D/B/A UBER AND RASIER, LLC JACOB G. LEAVITT NEVADA BAR NO. 12608 JASON C. BARRON NEVADA BAR NO. 7270 BIGHORN LAW ATTORNEYS FOR PLAINTIFF
JANICE M. MICHAELS
NICHOLAS F. ADAMS
NEVADA BAR NO. 14813
WOOD SMITH HENNING & BERMANATTORNEYS FOR UBER TECHNOLOGIES, INC. AND RASIER, LLC ERRONEOUSLY SUED AS UBER TECHNOLOGIES, INC. D/B/A UBER AND RASIER, LLC
JACOB G. LEAVITT
NEVADA BAR NO. 12608
JASON C. BARRON
NEVADA BAR NO. 7270
BIGHORN LAW
ATTORNEYS FOR PLAINTIFF
STIPULATION AND ORDER FOR DEFENDANTS, UBER TECHNOLOGIES, INC. AND RASIER, LLC TO RESPOND TO PLAINTIFF'S COMPLAINT
(FIRST REQUEST)
UBER TECHNOLOGIES, INC. and RASIER, LLC (collectively "Defendants") and CARLOS ROBERTS (hereinafter "Plaintiff") (collectively, "the Parties") by and through their respective counsel, hereby stipulate and agree that Defendants shall have until May 25, 2022 to respond to Plaintiff's Complaint. This extension would be the first extension of time granted for Defendants to respond to the Complaint.
I. Reasons For the Requested Extension
Plaintiff filed his Complaint on March 26, 2022 in the Eighth Judicial District Court of Nevada. See ECF No. 1. Subsequently, Defendants were served on or about March 28, 2022. See Id. Defendants thereafter timely filed a petition for removal on April 18, 2022. See Id. After the petition for removal was filed, the time to respond to the Complaint was extended to April 25, 2022. See FRCP Rule 81(c)(2)(C).
The parties are currently evaluating a potential resolution to this matter and Defendants' involvement in this matter. The parties anticipate that they will be able to reach a determination as to whether Defendants should be dismissed from this matter within 30 days. As such, the parties are seeking an extension for Defendants to respond to Plaintiff's Complaint so that unnecessary fees and costs may be avoided.
Accordingly, the Parties stipulate and agree that Defendants, UBER TECHNOLOGIES, INC. and RASIER, LLC shall have until May 25, 2022 to respond to Plaintiff's Complaint.
IT IS SO STIPULATED.
ORDER
The Court having reviewed the foregoing STIPULATION AND ORDER FOR DEFENDANTS, UBER TECHNOLOGIES, INC. AND RASIER, LLC TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST) in the above-entitled matter and for good cause appearing therefor:
IT IS SO ORDERED that Defendants, UBER TECHNOLOGIES, INC. and RASIER, LLC shall have until May 25, 2022 to respond to Plaintiff's Complaint.