Opinion
2:23-cv-1367
10-02-2023
MICHAEL WARWAS, on behalf of himself and all others similarly situated, Plaintiff, v. SPIRIT AIRLINES, INC., Defendant.
Kathryn L. Bain, State Bar No. 15496 BAIN MAZZA & DEBSKI LLP Monique Olivier (Pro Hac Vice to be Submitted) Cassidy Clark (Pro Hac Vice to be Submitted) OLIVIER & SCHREIBER LLP Anna D'Agostino (Pro Hac Vice to be Submitted) MILLER SHAH LLP Attorneys for Plaintiff and the Proposed Class
Kathryn L. Bain, State Bar No. 15496 BAIN MAZZA & DEBSKI LLP Monique Olivier (Pro Hac Vice to be Submitted) Cassidy Clark (Pro Hac Vice to be Submitted) OLIVIER & SCHREIBER LLP Anna D'Agostino (Pro Hac Vice to be Submitted) MILLER SHAH LLP Attorneys for Plaintiff and the Proposed Class
PLAINTIFF'S REQUEST TO EXTEND TIME FOR FILING OF VERIFIED PETITION AND DESIGNATION OF LOCAL COUNSEL (First Request)
ANDREW P. GORDON UNITED STATES DISTRICT JUDGE
Pursuant to the Court's Notice to Counsel Pursuant to Local Rule IA 11-2 (ECF No. 4) and Local Rule IA 6-1, Plaintiff Michael Warwas, by and through his undersigned counsel, hereby submits this request to extend the time for counsel for Plaintiff to file their Verified Petitions and Designations of Local Counsel, currently due September 15, 2023. This is Plaintiff's first request for an extension of time to file these documents.
On September 1, 2023, the Clerk of the Court entered a Notice to Counsel pursuant to Local Rule IA 11-12 instructing Plaintiff's out-of-state counsel, Anna D'Agostino, Cassidy Clark, and Monique Olivier, to comply with the completion and filing of the Verified Petition and Designation of Local Counsel by September 15, 2023.
An extension of time is necessary because Plaintiff's counsel, Monique Olivier, is currently out of the country and Anna D'Agostino is currently traveling and unavailable due to a family commitment. Thus, both attorneys are unable to obtain the Notary Public or Clerk of Court services required by the District Court of Nevada by the Court's deadline of September 15, 2023. (See Verified Petition for Permission to Practice In this Case Only By Attorney Not Admitted to the Bar of This Court And Designation of Local Counsel (“Verified Petition Form”), at p. 4 (requiring the signature of a Notary Public or Clerk of Court.) Additionally, all three attorneys seeking permission to practice in this case, Anna D'Agostino, Cassidy Clark, and Monique Olivier, are waiting on clerks of courts and state bars to issue certificates of good standing required by the Verified Petition Form at page 2, paragraph 3. This Request is made with good cause and not for purposes of delay. Each of Plaintiff's attorneys intend to submit the Verified Petitions and Designation of Local Counsel as soon as is practicable.
Given the length of Monique Olivier's commitment abroad, Plaintiff respectfully requests that the Court approve an extension of 45 days, to October 30, 2023.
IT IS SO ORDERED: