Opinion
2:21-cv-01173-JCM-EJY 2:22-cv-00740-JCM-EJY
04-10-2023
WEALTHY INC. and DALE BUCZKOWSKI, Plaintiffs, v. SPENCER CORNELIA, CORNELIA MEDIA LLC, and CORNELIA EDUCATION LLC, Defendants. WEALTHY INC. and DALE BUCZKOWSKI, Plaintiffs, v. JOHN MULVEHILL, JOHN ANTHONY LIFESTYLE, LLC, and OPTIMIZED LIFESTYLE LLC
TAMARA BEATTY PETERSON, ESQ., Bar No. 5218 tpeterson@petersonbaker.com NIKKI L. BAKER, ESQ., Bar No. 6562 nbaker@petersonbaker.com PETERSON BAKER, PLLC JEFFREY VOCKRODT, ESQ. (Admitted Pro Hac Vice) jvockrodt@cm.law DAVID JACOBY, ESQ. (Admitted Pro Hac Vice) djacoby@cm.law CULHANE MEADOWS PLLC Attorneys for Plaintiffs Wealthy Inc. and Dale Buczkowski
TAMARA BEATTY PETERSON, ESQ., Bar No. 5218 tpeterson@petersonbaker.com
NIKKI L. BAKER, ESQ., Bar No. 6562
nbaker@petersonbaker.com
PETERSON BAKER, PLLC
JEFFREY VOCKRODT, ESQ. (Admitted Pro Hac Vice) jvockrodt@cm.law
DAVID JACOBY, ESQ. (Admitted Pro Hac Vice) djacoby@cm.law
CULHANE MEADOWS PLLC
Attorneys for Plaintiffs Wealthy Inc. and Dale Buczkowski
STIPULATION TO EXTEND TIME AS TO THE RESPONSE TO OPTIMIZED LIFESTYLE'S MOTION FOR SUMMARY JUDGMENT PURSUANT TO FED. R. CIV. P. 56
(FIRST REQUEST)
Plaintiffs Wealthy Inc. and Dale Buczkowski ("Plaintiffs"), by and through their counsel of record, Peterson Baker PLLC and Culhane Meadows PLLC, Defendants John Mulvehill ("Mr. Mulvehill") and John Anthony Lifestyle, LLC ("JAL"), by and through their counsel of record, Kravitz Schnitzer Johnson & Watson, Chtd., Optimized Lifestyle, LLC ("OL"), by and through its counsel of record, Howard & Howard Attorneys, PLLC, and Spencer Cornelia, Cornelia Media, LLC, and Cornelia Education, LLC, by and through their counsel of record, Randazza Legal Group, PLLC, hereby submit this stipulation and order to extend the time for Plaintiffs to file their response to Optimized Lifestyle's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184]. This is the first stipulation for an extension of time to respond to Optimized Lifestyle's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184]OL filed its Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184] on March 20, 2023.
2. Pursuant to LR 7-2, the deadline to file and serve any response to a motion for summary judgment is 21 days after service of the motion.
3. The current deadline for Plaintiffs to file their response to OL's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184] is April 10, 2023.
4. Due to Plaintiffs' counsel's schedule, including the taking of a deposition on April 10, 2023, in another matter, Plaintiffs require additional time to file their response to OL's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184].
5. Good cause exists to extend the deadline for Plaintiffs to file their response to OL's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184].
6. The parties agree, subject to the Court's approval, that the deadline for Plaintiffs to file their response to OL's Motion for Summary Judgment Pursuant to Fed.R.Civ.P. 56 [ECF No. 184] shall be extended to April 12, 2023.
7. This stipulation is made in good faith and not for the purpose of delay.
IT IS SO STIPULATED.