Opinion
2:20-cv-00790-GMN-NJK
08-17-2023
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 Lewis Roca Rothgerber Christie LLP Steve Morris Robert F. Roos Rosa Solis-Rainey, VERISLAW, PLLC
Morris Law Group
Lewis Roca Rothgerber Christie LLP
Steve Morris
Robert F. Roos
Rosa Solis-Rainey,
VERISLAW, PLLC
STIPULATION TO EXTEND BY ONE WEEK THE DEADLINE FOR FILING REPLIES IN SUPPORT OF THE PARTIES' RESPECTIVE MOTIONS FOR PARTIAL SUMMARY JUDGMENT
(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 (“Surety Defendants”) file this Stipulation to Extend By One Week the Deadline to file their Respective Replies in support of their Motions for Partial Summary Judgment, and in support thereof, respectfully state as follows:
1. The Court's Order extending the deadlines in the Discovery Plan and Scheduling Order [ECF No. 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, Defandant/Counterclaimant/Surety Defendants and Plaintiff filed their respective Motions for Partial Summary Judgment on June 30, 2023 [ECF No. 103] and [ECF No. 106], respectively, (collectively, the “MPSJs”).
3. Consistent with the Court's July 27, 2023 order extending the time for the Parties to file their responses to the MPSJs to August 4, 2023 [ECF No. 115], the Parties filed their respective responses to the MPSJs on that date [ECF No. 116] and [ECF No. 117]. The current deadline for the parties to file their replies in support of their respective 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, is August 18, 2023.
4. This is the first stipulation for an extension of time presented by the parties to file their replies in support of their MPSJs, and the request is for an extension of one week until and including August 25, 2023.
5. The parties have been working diligently on their reply briefs and request this one-week extension based on the volume of information presented in the responses to the MPSJs, the significance of the issues presented by the dispositive nature of the relief requested, and their respective prior commitments and workloads.
7. This stipulation is filed before the August 18, 2023 deadline consistent with Local Rule IA -6.1, and is further submitted in good faith and not intended to cause delay. With the extension requested herein, the MPSJs will be fully briefed well before the settlement conference scheduled for September 28, 2023.
8. Consistent with Local Rule IA 6-2, SMM, JE Dunn and the Surety Defendants respectfully request that the Court extend the time for them to file their replies in support of their respective MPSJs until and including August 25, 2023.
ORDER
IT IS SO ORDERED.