Opinion
2:20-cv-01625-APG-NJK
02-27-2023
John P. Aldrich, Esq. Nevada Bar No. 6877 Catherine Hernandez, Esq. Nevada Bar No. 8410 ALDRICH LAW FIRM, LTD. Attorneys for Defendant JOSEPH A. GUTIERREZ, ESQ. Nevada Bar No. 9046 JEAN-PAUL HENDRICKS, ESQ. Nevada Bar No. 10079 Attorneys for Plaintiff/Counterdefendant Tasty One, LLC d/b/a Earth Smarte Water of Las Vegas
John P. Aldrich, Esq.
Nevada Bar No. 6877
Catherine Hernandez, Esq.
Nevada Bar No. 8410
ALDRICH LAW FIRM, LTD.
Attorneys for Defendant
JOSEPH A. GUTIERREZ, ESQ.
Nevada Bar No. 9046
JEAN-PAUL HENDRICKS, ESQ.
Nevada Bar No. 10079
Attorneys for Plaintiff/Counterdefendant Tasty One, LLC d/b/a Earth Smarte Water of Las Vegas
STIPULATION TO EXTEND THE DEADLINE TO FILE REPLY TO RESPONSE TO DEFENDANT'S RENEWED MOTION TO DEDESIGNATE DOCUMENTS DISCLOSED BY PLAINTIFF AND MARKED AS “HIGHLY CONFIDENTIALATTORNEY'S EYES ONLY” PURSUANT TO PROTECTIVE ORDER AND FOR A DECLARATION THAT THE “HIGHLY CONFIDENTIAL-ATTORNEY'S EYES ONLY” DESIGNATION DOES NOT APPLY [ECF NO. 112]
(FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED, by and between the parties, Plaintiff Tasty One, LLC d/b/a Earth Smarte Water of Las Vegas (“Plaintiff”), by and through its attorneys of record, the law firm MAIER GUTIERREZ & ASSOCIATES and Defendant Earth Smarte Water, LLC d/b/a DENCOH20 (“Defendant”), by and through its attorney of record, John P. Aldrich, Esq., of the Aldrich Law firm, Ltd., as follows:
On February 3, 2023, Defendant filed its Renewed Motion to De-Designate Documents Disclosed by Plaintiff and Marked as “Highly Confidential-Attorney's Eyes Only” Pursuant to Protective Order and for a Declaration that the “Highly Confidential-Attorney's Eyes Only” Designation Does Not Apply [ECF No. 112] (“Renewed Motion to De-Designate Documents”). On February 17, 2023, Plaintiff filed its Response to Defendant's Renewed Motion to De-Designate Documents [ECF No. 116]. The current deadline for Defendant to file its Reply in support of its Renewed Motion to De-Designate Documents is February 24, 2023.
Because of extensive recent and existing commitments of Defendant's counsel, Defendant's counsel requested and the parties have agreed to extend the time for Defendant to file its Reply in support of its Renewed Motion to De-Designate Documents to March 3, 2023.
This stipulation is submitted in good faith and not for purposes of delay. It is the first request for an extension of this deadline. The bench trial in this matter is curerently scheduled on June 26, 2023. A settlement conference is currently scheduled in this matter on April 4, 2023. This stipluation does not in any way interfere with or cause a delay in these existing deadlines.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED