Opinion
2:20-cv-00790-GMN-NJK
07-20-2023
UNITED STATES OF AMERICA, for the use and benefit of SUSTAINABLE MODULAR MANAGEMENT, INC., a Texas corporation Plaintiff, v. JE DUNN CONSTRUCTION COMPANY, et al., Defendants.
MORRIS LAW GROUP Michael S. Alfred Steve Morris, Bar Rosa Solis-Rainey, Michael S. Alfred (pro hac vice) VerisLaw, PLLC Attorneys for Plaintiff LEWIS ROCA ROTHGERBER CHRISTIE LLP Robert F. Roos (pro hac vice) Attorneys for Defendant
MORRIS LAW GROUP Michael S. Alfred Steve Morris, Bar Rosa Solis-Rainey, Michael S. Alfred (pro hac vice) VerisLaw, PLLC Attorneys for Plaintiff
LEWIS ROCA ROTHGERBER CHRISTIE LLP Robert F. Roos (pro hac vice) Attorneys for Defendant
STIPULATION TO EXTEND BY ONE WEEK THE DEADLINE FOR RESPONDING TO THE RESPECTIVE MOTIONS FOR PARTIAL SUMMARY JUDGMENT FILED BY PLAINTIFFS AND DEFENDANTS (FIRST REQUEST)
Plaintiff, UNITED STATES OF AMERICA, for the use and benefit of Sustainable Modular Management, Inc. (“SMM” or “Plaintiff”), Defendant/Counterclaimant, JE Dunn Construction Company, and Defendants, Federal Insurance Company, Hartford Fire Insurance Company, Travelers Casualty and Surety Company of America (“Defendants”) file this Stipulation to Extend By One Week the Deadline to Respond to their Respective Motions for Partial Summary Judgment, and in support thereof, respectfully state as follows:
RECITALS
1. The Court's Order extending the deadlines in the Discovery Plan and Scheduling Order [Dkt. 95] and Local Rules reset the deadline for the parties to file dispositive motions to June 30, 2023.
2. Consistent with the Court's Order and Local Rules, Defendants/Counterclaimant and Plaintiff filed their respective Motions for Partial Summary Judgment on June 30, 2023 [Dkt. 103] and [Dkt. 106], respectively, (collectively, the “MPSJs”).
3. July 21, 2023 is the current deadline for the parties to file their responses to the MPSJs consistent with LR 7-2 of the Local Rules for the United States District Court, District of Nevada and Rule 56 of the Federal Rules of Civil Procedure.
4. This is the first stipulation for an extension of time presented by the parties to respond to the MPSJs, and the request is for an extension of one week until and including July 28, 2023.
5. The parties have been working diligently on their response briefs and request this one-week extension based on the volume of information presented in the MPSJs and the significance of the issues presented by the dispositive nature of the relief requested. Additionally, SMM's counsel has a college fair and activities for the start of school for his teenage daughter today (on July 20, 2023) and sports-related activities for his son tomorrow (July 21, 2023), along with a heavy workload since June 30, 2023 that has included multiple settlement conferences (including a mediation out of town), depositions, responding to and serving written discovery, preparing appellate briefs, and preparing and finalize expert reports in other cases. If this stipulation is granted, it will allow Plaintiff's counsel to participate in the college fair and sports activities with his family.
6. Defendants' and Counterclaimant's counsel has a work-related conference out of town today and tomorrow. July 20-21, 2023, along with a heavy workload in other matters. 7. This stipulation is filed before the July 21, 2023 deadline consistent with Local Rule IA -6.1, and is further submitted in good faith and not intended to cause delay.
8. Consistent with Local Rule IA 6-2, SMM and JE Dunn respectfully request that the Court extend the time for to respond the MPSJs until and including July 28, 2023.
ORDER
IT IS SO ORDERED.