Opinion
3:21-cv-00352-MMD-CSD
08-21-2023
LUCERO SANCHEZ, Plaintiff, v. RENOWN HEALTH, a non-profit Nevada Corporation, and DOES 1-20, inclusive, Defendant.
BY: Sandra Ketner Simons Hall Johnston PC Luke Busby, Esq.
BY: Sandra Ketner
Simons Hall Johnston PC
Luke Busby, Esq.
STIPULATION AND ORDER TO EXTEND DEADLINE FOR RESPONSE TO MOTION FOR SUMMARY JUDGMENT
[FIRST REQUEST]
Plaintiff Lucero Sanchez (“Plaintiff' or “Sanchez”) and Defendant Renown Health (“Defendant” or “Renown”) (collectively, the “Parties”), by and through their respective counsel, hereby stipulate and agree that the deadline for the Plaintiff to respond to the Defendant's August 11, 2023 Motion for Summary Judgment [ECF #69] be extended by a period of fourteen (14) days for to September 15, 2023.
The undersigned counsel for the Plaintiff has several other matters that have deadlines around the existing deadline to respond to the Defendant's motion, including an opening brief before the Nevada Supreme Court that is due on August 28, 2023. Further, the motion contains intricate factual and legal arguments that will require extensive time to respond to. Thus, the parties request that the Court grant the Plaintiff additional time to adequately respond to the motion.