Opinion
2:22-cv-02174-GMN-DJA
01-09-2023
SANDRA TOCCI, as Special Administrator and Personal Representative of the Estate of Frank E. Tocci, Deceased; and Sandra Tocci, as Heir and Mother of FRANK E. TOCCI, Deceased, Plaintiff, v. CORECIVIC, INC., f/k/a/ CORRECTIONS CORPORATION OF AMERICA; CORECIVIC OF TENNESSEE, LLC; BRIAN KOEHN, Warden, Nevada Southern Detention Center; DOE INDIVIDUALS I-XXV; ROE ENTITIES I-X, inclusive, Defendants.
LAW OFFICES OF MICHAEL GOWDEY Michael I. Gowdey Attorneys for Plaintiff STRUCK LOVE BOJANOWSKI & ACEDO, PLC Ashlee B. Hesman Gina G. Winspear DENNETT WINSPEAR Attorneys for Defendants CoreCivic, Inc. and CoreCivic of Tennessee
LAW OFFICES OF MICHAEL GOWDEY Michael I. Gowdey Attorneys for Plaintiff
STRUCK LOVE BOJANOWSKI & ACEDO, PLC Ashlee B. Hesman Gina G. Winspear DENNETT WINSPEAR Attorneys for Defendants CoreCivic, Inc. and CoreCivic of Tennessee
STIPULATION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST)
Pursuant to LR IA 6-1, the parties stipulate to extend the deadline for Defendants CoreCivic & CoreCivic of Tennessee to respond to Plaintiff's Complaint, which was recently removed to this Court from the Fifth Judicial District Court for Nye County on December 30, 2022. This is the first stipulation for extension of time for Defendants to respond to Plaintiff's Complaint.
Defendants' current deadline to file a responsive pleading is January 6, 2023. The parties stipulate to extend this deadline to January 20, 2023, to allow time to meet and confer regarding possible dismissal of some of Plaintiff's claims. This additional time is needed, in part, because Plaintiff's counsel just returned from traveling outside the county. As such, and to streamline this litigation, and avoid unnecessary motion practice and Court intervention, the parties stipulate to extend the deadline for Defendants to respond to Plaintiff's Complaint from January 6 to January 20, 2023. This brief requested extension is made in good faith and not for purposes of delay.
IT IS SO ORDERED.