Opinion
3:21-cv-495-RCJ-CSD
08-01-2022
JUAN ULLOA, Plaintiff, v. NEVADA GOLD MINES, a Delaware Limited Liability Company, Defendant.
JAMES P. KEMP, ESQ. KEMP & KEMP Attorney for Plaintiff JUAN ULLOA SIMONS HALL JOHNSTON PC Anthony L. Hall, Esq. Jonathan A. McGuire, Esq. Attorneys for Defendant
JAMES P. KEMP, ESQ.
KEMP & KEMP
Attorney for Plaintiff JUAN ULLOA
SIMONS HALL JOHNSTON PC
Anthony L. Hall, Esq.
Jonathan A. McGuire, Esq.
Attorneys for Defendant
STIPULATION AND ORDER TO EXTEND PLAINTIFF'S TIME TO RESPOND TO DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO REQUESTS FOR ADMISSIONS OR ALTERNATIVELY TO WITHDRAW ADMISSIONS PURSUANT TO FRCP 36(b) (ECF NO. 40)
(FIRST REQUEST)
Defendant, Nevada Gold Mines, LLC (“Defendant” or “NGM”), by and through its counsel of record, ANTHONY HALL and JONATHAN MCGUIRE of SIMONS HALL JOHNSTON, and Plaintiff Juan Ulloa, (“Plaintiff”) by and through his counsel of record, J.P. KEMP of KEMP & KEMP, hereby stipulate and agree to extend the deadline for Plaintiff to file his Response to NGM's Motion (ECF No. 40) that seeks an enlargement of time to respond to Requests for Admissions or alternatively to withdraw admissions pursuant to FRCP Rule 36(b). The response, currently due on July 29, 2022, will be extended by two (2) weeks to and including August 12, 2022.
The reason for the extension, as Plaintiff's counsel has informed Defense Counsel is that Plaintiff's counsel had another significant briefing deadline due on July 29, 2022 and in the two weeks since Defendant's motion was filed Plaintiff's counsel has been tied up preparing for two party Rule 30(b)(6) depositions and a significant workers' compensation appeal hearing. Also, Plaintiff's counsel was out of the country on vacation until July 20, 2022 when he returned to the office. More time is needed to address the matters set forth in Defenant's motion.
This is the parties first request for an extension of time for Plaintiff to respond to Defendant's motion (ECF No. 40) and is made in good faith and not for the purpose of delay.
ORDER
IT IS SO ORDERED.