Opinion
2:21-cv-01123-APG-BNW
02-22-2023
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. Carmona, Esq., Kristopher S. Pre, Esq., Attorneys for Plaintiff Peggy Thornton. SNELL & WILMER L.L.P., Amy F. Sorenson, Esq., SNELL & WILMER L.L.P., Kelly H. Dove, Esq., SNELL & WILMER L.L.P., Attorneys for Defendant Apartment Management Consultants, LLC.
NEVADA LEGAL SERVICES, INC., Elizabeth S. Carmona, Esq., Kristopher S. Pre, Esq., Attorneys for Plaintiff Peggy Thornton.
SNELL & WILMER L.L.P., Amy F. Sorenson, Esq., SNELL & WILMER L.L.P., Kelly H. Dove, Esq., SNELL & WILMER L.L.P., Attorneys for Defendant Apartment Management Consultants, LLC.
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE RESPONSE TO COMPLAINT (SECOND 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 stipulate and agree to extend AMC's deadline to file its response to Plaintiff's Complaint [ECF No. 1] from February 21, 2023, to March 10, 2023 for the following reasons:
1. Plaintiff filed the Complaint on June 14, 2021 [ECF No. 1].
2. The Complaint was unsealed on December 9, 2022 upon the United States' declining intervention [ECF No. 18].
3. AMC's response to the Complaint was originally due on January 18, 2023.
4. The Parties had informally agreed to extend the deadline to respond to February 1, 2023 prior to AMC's retaining counsel.
5. Undersigned counsel, Snell & Wilmer L.L.P. was retained to represent AMC on or about January 26, 2023.
6. The Parties previously stipulated to extend the deadline for AMC to respond to the Complaint to and including February 21, 2023.
7. The Parties now agree to allow AMC an additional extension of time to respond to the Complaint, which request is supported by good cause.
8. While AMC and its counsel have worked diligently to evaluate the allegations in the Complaint, they require modest additional time.
9. As AMC is not presently the property manager, it is taking additional time to locate relevant documentation. At the same time, undersigned counsel and their core litigation team has faced some personal obstacles that have impeded their ability to work, including the post-partum hospitalization of a spouse and a school-age child currently suffering from COVID.
10. No other defendant has yet appeared. 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 March 10, 2023.
ORDER
IT IS SO ORDERED