Opinion
2:21-cv-01123-APG-BNW
02-07-2023
UNITED STATES OF AMERICA ex rel. PEGGY THORNTON, Realtor, and PEGGY THORNTON, Plaintiff, v. PORTOLA DEL SOL OPERATOR, LLC, a foreign limited-liability company; TMIF II PORTOLA, LLC, a foreign limited-liability company; APARTMENT MANAGEMENT CONSULTANTS, LLC, a foreign limited liability company; and RENE RICHARDSON, as AGENT of PORTOLA DEL SOL OPERATOR, LLC, Defendants.
NEVADA LEGAL SERVICES, INC. ELIZABETH S. CARDONA, ESQ. KRISTOPHER S. PRE, ESQ. ATTORNEYS FOR PLAINTIFF PEGGY THORNTON SNELL & WILMER L.L.P. AMY F. SORENSON, ESQ. NEVADA BAR NO. 12495 SNELL & WILMER L.L.P. KELLY H. DOVE, ESQ. NEVADA BAR NO. 10569 SNELL & WILMER L.L.P ATTORNEYS FOR DEFENDANT APARTMENT MANAGEMENT CONSULTANTS, LLC
NEVADA LEGAL SERVICES, INC. ELIZABETH S. CARDONA, ESQ. KRISTOPHER S. PRE, ESQ. ATTORNEYS FOR PLAINTIFF PEGGY THORNTON
SNELL & WILMER L.L.P. AMY F. SORENSON, ESQ. NEVADA BAR NO. 12495 SNELL & WILMER L.L.P. KELLY H. DOVE, ESQ. NEVADA BAR NO. 10569 SNELL & WILMER L.L.P ATTORNEYS FOR DEFENDANT APARTMENT MANAGEMENT CONSULTANTS, LLC
JOINT MOTION AND PROPOSED ORDER TO EXTEND DEADLINE TO FILE RESPONSE TO COMPLAINT (FIRST REQUEST)
BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE
Plaintiff Peggy Thornton (“Plaintiff”) and Defendant Apartment Management Consultants, LLC (“Defendant” or “AMC”) (collectively, the “Parties”), by and through their undersigned counsel, for good cause shown, hereby jointly move and agree to extend AMC's deadline to file its response to Plaintiff's Complaint [ECF No. 1] from January 18, 2023, to February 21, 2023 for the following reasons:
1. Plaintiff filed the Complaint on June 14, 2021 [ECF No. 1].
2. AMC's response to the Complaint was originally due on January 18, 2023.
3. The Parties informally agreed to extend the deadline to respond to February 1, 2023.
4. Undersigned counsel, Snell & Wilmer L.L.P. was retained to represent AMC on or about January 26, 2023.
5. The Parties jointly move and agree to extend the deadline for AMC to respond to the Complaint to and including February 21, 2023.
6. This extension request is supported by good cause. Specifically, as AMC's counsel was just retained, they require sufficient time to evaluate and investigate the allegations in the Complaint. Additionally, AMC's lead counsel has a trial beginning on February 8, 2023, which will require substantial time.
7. This extension request is sought in good faith and is not made for the purpose of delay.
THEREFORE, the Parties respectfully request an extension for AMC to file its response to the Complaint until February 21, 2023.
ORDER
IT IS SO ORDERED.