Opinion
2:22-cv-1904-APG-NJK
12-16-2022
PATRICIA SOMERS, as trustee[1] for the Valesco Irrevocable Trust dated June 16, 2004, Plaintiff, v. MIDLAND NATIONAL LIFE INSURANCE COMPANY, Defendant.
HOLLEY DRIGGS F. THOMAS EDWARDS, ESQ. NEVADA BAR NO. 9549 JESSICA M. LUJAN, ESQ. NEVADA BAR NO. 14913 ATTORNEYS FOR DEFENDANT MIDLAND NATIONAL LIFE INSURANCE COMPANY LEE KIEFER & PARK, LLP MATTHEW W. PARK, ESQ. NEVADA BAR NO. 12062 T. CHASE PITTSENBARGER, ESQ. NEVADA BAR NO. 13740 ATTORNEYS FOR PLAINTIFF, PATRICIA SOMERS, TRUSTEE
HOLLEY DRIGGS F. THOMAS EDWARDS, ESQ. NEVADA BAR NO. 9549 JESSICA M. LUJAN, ESQ. NEVADA BAR NO. 14913 ATTORNEYS FOR DEFENDANT MIDLAND NATIONAL LIFE INSURANCE COMPANY
LEE KIEFER & PARK, LLP MATTHEW W. PARK, ESQ. NEVADA BAR NO. 12062 T. CHASE PITTSENBARGER, ESQ. NEVADA BAR NO. 13740 ATTORNEYS FOR PLAINTIFF, PATRICIA SOMERS, TRUSTEE
STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S MOTION FOR REMAND (ECF NO. 9) (FIRST REQUEST)
Midland National Life Insurance Company, the defendant in this removed action (“Midland”), by and through its counsel of record, the law firm of Holley Driggs, and Plaintiff Patricia Somers, as trustee for the Valesco Irrevocable Trust dated June 16, 2004 (“Plaintiff”), by and through her counsel of record, the law firm of Lee Kiefer & Park, LLP, hereby stipulate and agree as follows:
1. On December 12, 2022, Plaintiff filed her Motion for Remand (ECF No. 9).
2. The current deadline for Midland to respond to the Motion for Remand is December 26, 2022 (the “Response Deadline”).
3. Because the Response Deadline is the day after the Christmas holiday, the parties agreed that a two-week extension of the Response Deadline is appropriate.
4. Accordingly, the parties stipulate and agree that the Response Deadline shall be extended to January 9, 2023. This is the parties' first request for an extension of this deadline, and such request is not meant for the purpose of causing undue delay.
ORDER
IT IS SO ORDERED.