Opinion
2:20-cv-00790-GMN-NJK
07-27-2023
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 MORRIS LAW GROUP BY MICHAEL S. ALFRED STEVE MORRIS, ROSA SOLIS-RAINEY, ATTORNEYS FOR PLAINTIFF SUSTAINABLE MODULAR MANAGEMENT, INC LEWIS ROCA ROTHGERBER CHRISTIE LLP ROBERT F. ROOS ATTORNEYS FOR DEFENDANTS JE DUNN CONSTRUCTION COMPANY, FEDERAL INSURANCE COMPANY, HARTFORD FIRE INSURANCE COMPANY, AND DEFENDANTS TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA
MORRIS LAW GROUP MORRIS LAW GROUP BY MICHAEL S. ALFRED STEVE MORRIS, ROSA SOLIS-RAINEY, ATTORNEYS FOR PLAINTIFF SUSTAINABLE MODULAR MANAGEMENT, INC
LEWIS ROCA ROTHGERBER CHRISTIE LLP ROBERT F. ROOS ATTORNEYS FOR DEFENDANTS JE DUNN CONSTRUCTION COMPANY, FEDERAL INSURANCE COMPANY, HARTFORD FIRE INSURANCE COMPANY, AND DEFENDANTS TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA
JOINT STIPULATION TO EXTEND BY ONE WEEK THE DEADLINE FOR RESPONDING TO THE RESPECTIVE MOTIONS FOR PARTIAL-SUMMARY JUDGMENT FILED BY PLAINTIFFS AND DEFENDANTS (SECOND REQUEST)
Plaintiff, UNITED STATES OF AMERICA, for the use and benefit of Sustainable Modular Management, Inc. (“SMM” or “Plaintiff”), and Defendant/Counterclaimant, JE Dunn Construction Company, Federal Insurance Company, Hartford Fire Insurance Company, and Defendants 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] reset the deadline to June 30, 2023 for the parties to file dispositive motions.
2. Consistent with the Court's Order, both Defendants and Plaintiff filed their respective Motions for Partial Summary Judgment on June 30, 2023 [Dkt. 103] and [Dkt. 106], respectively, (collectively, the “MPSJs”).
3. On July 20, 2023, the Parties filed their Stipulation for Extension of Time for One Week to Respond to the MPSJs (First Request) [110] (the “Stipulation”). That same day, the Court granted the extension of time to July 28, 2023 for the parties to respond to the respective MPSJs [Dkt. 112].
4. This is the second stipulation for an extension of time presented by the parties to respond to the MPSJs. This request is for a one-week extension until and including August 4, 2023. The parties do not anticipate requesting any further extensions.
5. When the first stipulation was submitted on July 20, 2023, the parties believed a one-week extension would be sufficient. However, while continuing to work diligently on their responses, it has become apparent that an additional week is necessary to properly and fairly complete their response briefs given the complexity of the legal issues presented and the voluminous factual record that includes multiple appendices (for example, one declaration in the summary-judgment record is twelve pages and eighty-two paragraphs in length).
6. This stipulation is filed before the July 28, 2023 deadline consistent with Local Rule IA -6.1, and is further submitted in good faith and not intended to cause delay.
7. 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 August 4, 2023.
ORDER
IT IS SO ORDERED.