Opinion
2:20-cv-00205-JCM-DJA
10-31-2022
TROY CAPITAL LLC, a Nevada Limited Liability Company, Plaintiff, v. PATENAUDE & FELIX APC, et al., Defendants. PATENAUDE & FELIX APC, Counterclaimant/Third-Party Plaintiff v. TROY CAPITAL LLC, a Nevada Limited Liability Company; RANCE WILLEY, an Individual, and TROY DUPUIS, an Individual, Counterdefendants/Third-Party Defendants
The Hon. Daniel J. Albregts DALE K. KLEVEN, ESQ. Nevada Bar No. 007778 THOMAS M. FRONCZEK, ESQ. Nevada Bar No. 11380 RELIEF LAWYERS, LLC TOMIO B. NARITA, ESQ. (pro hac vice) California Bar No. 156576 R. TRAVIS CAMPBELL, ESQ. (pro hac vice) California Bar No. 271580 SIMMONDS & NARITA LLP Attorneys for Plaintiff and Counter-Defendant Troy Capital, LLC and Third-Party Defendants Rance Willey and Troy Dupuis SANTORO WHITMIRE Nicholas J. Santoro Nevada Bar No. 0532 Jason D. Smith Nevada Bar No. 9691 Attorneys for Counterclaimant/Third-Party Plaintiff PATENAUDE & FELIX APC LEWIS BRISBOIS BISGAARD & SMITH LLP Jeffrey D. Olster Nevada Bar No. 8864 Attorneys for Defendants PATENAUDE & FELIX APC, RAYMOND A. PATENAUDE, MICHAEL D. KAHN and ANGIE HONG HOAR
Current Deadline: October 31, 2022
New Deadline: November 7, 2022
The Hon. Daniel J. Albregts
DALE K. KLEVEN, ESQ.
Nevada Bar No. 007778
THOMAS M. FRONCZEK, ESQ.
Nevada Bar No. 11380
RELIEF LAWYERS, LLC
TOMIO B. NARITA, ESQ. (pro hac vice)
California Bar No. 156576
R. TRAVIS CAMPBELL, ESQ. (pro hac vice)
California Bar No. 271580
SIMMONDS & NARITA LLP
Attorneys for Plaintiff and Counter-Defendant Troy Capital, LLC and Third-Party Defendants Rance Willey and Troy Dupuis
SANTORO WHITMIRE
Nicholas J. Santoro Nevada Bar No. 0532
Jason D. Smith Nevada Bar No. 9691
Attorneys for Counterclaimant/Third-Party Plaintiff PATENAUDE & FELIX APC
LEWIS BRISBOIS BISGAARD & SMITH LLP
Jeffrey D. Olster Nevada Bar No. 8864
Attorneys for Defendants PATENAUDE & FELIX APC, RAYMOND A. PATENAUDE, MICHAEL D. KAHN and ANGIE HONG HOAR
STIPULATION TO EXTEND TIME TO RESPOND TO DEFENDANTS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND WITNESS DEPOSITION
DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE
Pursuant to LR IA 6-1, LR IA 6-2, and LR 7-1, the parties, through their respective counsel, stipulate to extend the time for Plaintiff to respond to Defendants' pending Motion to Compel Production of Documents and Witness Deposition (ECF No. 150), which was filed on October 17, 2022. This is the parties' first request. Good cause for this stipulation exists based on the following:
1. On October 17, 2022, Defendants filed a Motion to Compel Production of Documents and Witness Deposition. ECF No. 150. The motion seeks to compel Troy Capital to Produce various documents and compel nonparty Kelly MacBeth to appear for deposition.
2. Pursuant to the Court's Local Rules, Plaintiff and Ms. MacBeth's deadline to oppose the motion is October 31, 2022. L.R. 7-2(b). Defendants' deadline to file their reply is November 7, 2022. Id.
3. Good cause exists for the brief one-week extension of the deadlines. Lead counsel for Plaintiff and Ms. MacBeth, Tomio Narita, has been travelling out-of-state during the week of October 24 and has been simultaneously dealing with several pressing deadlines in other matters. As a result, counsel has not had sufficient time to dedicate to preparing the opposition briefs. In addition, co-counsel for Plaintiff and Ms. MacBeth who is assisting with the preparation of the opposition briefs, R. Travis Campbell, tested positive and was recovering from COVID-19 during the week of October 17. Accordingly, Plaintiff and Ms. MacBeth have requested, and Defendants have agreed, to extend the opposition deadline to the Motion to Compel by one week to November 7, 2022.
4. Accordingly, the parties hereby stipulate and jointly request that the Court extend the deadline for Plaintiff and Ms. MacBeth to respond to Defendants' Motion to Compel Production of Documents and Witness Deposition (ECF No. 127) to November 7, 2022, and extend the deadline for Defendants to file their reply to November 14, 2022.
5. This requested extension of time is not sought for delay or any other improper purpose. The parties respectfully submit that the reasons set forth above constitute good cause for the extension.
IT IS SO ORDERED: