Opinion
3:21-cv-00238-HDM-CSD
12-19-2022
LYNN THOMPSON, Plaintiff, v. TESLA MOTORS, INC.; ONQGLOBAL, INC.; DOES 1-50, Defendants.
HKM EMPLOYMENT ATTORNEYS, LLP JENNY L. FOLEY, PHD., ESQ. ATTORNEY FOR PLAINTIFF LYNN THOMPSON JACKSON LEWIS P.C. JOSHUA A. SLIKER, ESQ. KYLE J. HOYT, ESQ. ATTORNEYS FOR DEFENDANT TESLA MOTORS, INC. FENNEMORE CRAIG, P.C. WADE BEAVERS, ESQ. ATTORNEYS FOR DEFENDANT ONQ GLOBAL, INC.
HKM EMPLOYMENT ATTORNEYS, LLP JENNY L. FOLEY, PHD., ESQ. ATTORNEY FOR PLAINTIFF LYNN THOMPSON
JACKSON LEWIS P.C. JOSHUA A. SLIKER, ESQ. KYLE J. HOYT, ESQ. ATTORNEYS FOR DEFENDANT TESLA MOTORS, INC.
FENNEMORE CRAIG, P.C. WADE BEAVERS, ESQ. ATTORNEYS FOR DEFENDANT ONQ GLOBAL, INC.
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO PLAINTIFF'S MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT
(FIRST REQUEST)
IT IS HEREBY STIPULATED by and between Plaintiff Lynn Thompson (“Plaintiff'), through his counsel HKM Employment Attorneys, LLP, Defendant Tesla Motors, Inc. (“Tesla”), through its counsel Jackson Lewis P.C., and Defendant OnQ Global, Inc. (“OnQ”) (collectively, “Defendants”), that Defendants shall have an extension of time up to and including Thursday, January 5, 2023, in which to file a response to Plaintiff's Motion for Leave to File First Amended Complaint. This Stipulation is submitted and based upon the following:
1. Plaintiff filed his Motion for Leave to File First Amended Complaint on December 5, 2022, seeking to add an additional cause of action under Section 11(c) of the OSH Act of 1970. ECF No. 78.
2. Defendants are preparing their respective responses to Plaintiff's Motion. However, the press of other matters, including multiple depositions and emergency motion practice, have delayed Tesla's counsel's preparation of the opposition and as such, additional time is necessary. Counsel for Tesla also needs additional time to confer with Tesla's representatives regarding Plaintiff's Motion and Tesla's opposition thereto. OnQ seeks an extension for the same reasons.
3. This is the first request for an extension of time for Defendants to file a response to Plaintiff's Motion for Leave to File First Amended Complaint.
4. This request is made in good faith and not for the purpose of delay.
5. Nothing in this Stipulation, nor the fact of entering to the same, shall have the effect of or be construed as waiving any claim or defense held by any party hereto.
ORDER
IT IS SO ORDERED: