Opinion
2:22-cv-02045-GMN-DJA
01-25-2023
TOPOLEWSKI AMERICA, INC., a Nevada corporation, Plaintiff, v. STATE OF CALIFORNIA EMPLOYMENT DEVELOPMENT DEPARTMENT, and DOES 1-10, inclusive, Defendants.
McDONALD CARANO LLP Rory T. Kay Pat Lundvall (NSBN 3761) Rory T. Kay (NSBN 12416) Kiley A. Harrison (NSBN 16092) Attorneys for Defendant BLUT LAW GROUP, PC Elliot S. Blut Elliot S. Blut (NSBN. 6570) Attorneys for Plaintiff
McDONALD CARANO LLP
Rory T. Kay
Pat Lundvall (NSBN 3761)
Rory T. Kay (NSBN 12416)
Kiley A. Harrison (NSBN 16092)
Attorneys for Defendant
BLUT LAW GROUP, PC
Elliot S. Blut
Elliot S. Blut (NSBN. 6570)
Attorneys for Plaintiff
STIPULATION AND ORDER EXTENDING DEADLINE FOR DEFENDANT TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST)
Pursuant to Local Rules IA 6-1 and 7-1, Defendant State of California Employment Development Department (“EDD”) and Plaintiff Topolewski America, Inc. (“Topolewski”) stipulate, agree, and respectfully request that the Court extend the deadline for EDD to respond to Topolewski's Complaint from January 26, 2023 to February 9, 2023. In support of this Stipulation, the parties jointly state as follows:
1. On December 9, 2022, Topolewski filed this action in the United States District Court for the District of Nevada, Case No. 2:22-cv-02045-GMN-DJA, asserting conversion and abuse of process claims and seeking preliminary and permanent injunctive relief. (ECF No. 1).
2. On December 14, 2022, Topolewski served EDD with process. (ECF No. 6).
3. The parties thereafter agreed to extend the deadline for EDD to respond to Topolewski's Complaint from January 4, 2023 to January 26, 2023.
4. EDD retained McDonald Carano LLP as counsel for this matter. EDD's counsel needs additional time to investigate and prepare an appropriate response to Topolewski's Complaint.
5. This is EDD's first request to this Court for an extension of time to respond to Topolewski's Complaint, the request is in good faith and not for the purposes of delay, and the requested extension will not prejudice any party.
6. WHEREFORE, the parties stipulate, agree, and respectfully request that the Court extend the deadline for EDD to respond to Topolewski's Complaint from January 26, 2023 to February 9, 2023.
IT IS SO ORDERED.