Opinion
2:22-cv-01964-APG-EJY
02-21-2023
LANCE D. STUCKEY, JR., Individually and on behalf of all others similarly situated, Plaintiffs, v. APEX MATERIALS, LLC, ELKHORN ENVIRONMENTAL, LLC, WERDO BC, INC., WERDCO LLC, BRENT CONRAD, BRANDON CONRAD, PATRICIA CONRAD, LAS VEGAS PAVING CORPORATION, TAB CONTRACTORS, INC., WILLIAM CHARLES CONSTRUCTION COMPANY, HARBER COMPANY, INC., John Does I to XX, name fictitious true name and of persons being unkwn, and XYZ Corporations I to XX, name fictitious true name of of entities being unkwn, Defendants.
Nicole E. Lovelock, Esq. Nevada State Bar No. 11187 Donna DiMaggio, Esq. Nevada State Bar No. 9794 JONES LOVELOCK Attorneys for Defendant, TAB CONTRACTORS, INC. Leon Greenberg, Esq. Nevada Bar No. 8094 Ruthann Devereaux-Gonzalez, Esq. Nevada Bar No. 15904 LEON GREENBERG PROFESSONAL CORPORATION Attorneys for Plaintiff Lance D. Stuckey, Jr.
Nicole E. Lovelock, Esq. Nevada State Bar No. 11187 Donna DiMaggio, Esq. Nevada State Bar No. 9794 JONES LOVELOCK Attorneys for Defendant, TAB CONTRACTORS, INC.
Leon Greenberg, Esq. Nevada Bar No. 8094 Ruthann Devereaux-Gonzalez, Esq. Nevada Bar No. 15904 LEON GREENBERG PROFESSONAL CORPORATION Attorneys for Plaintiff Lance D. Stuckey, Jr.
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANT TAB CONTRACTORS, INC. TO FILE RESPONSIVE PLEADING TO COMPLAINT
[FIRST REQUEST]
Plaintiff, LANCE D. STUCKEY, JR. (“Plaintiff”) and Defendant, TAB CONTRACTORS, INC. (“Defendant”) by and through their undersigned counsel, hereby agree and stipulate to extend the time for Defendant to file a response to the Complaint from the current deadline of January 26, 2023, up to and including March 27, 2023. In exchange for the sixty (60) day extension to respond, Defendant agrees not to dispute service of process.
This is the first request for an extension of time to respond to the Complaint. The request is necessary because counsel for Defendant was recently retained and needs additional time to investigate the allegations and prepare a response to the Complaint. Further, the parties are exploring possible early resolution of the matter. This request is made in good faith and not for the purposes of delay.
IT IS SO ORDERED.