Kwasniewski et al v. sanofi-aventis U.S., LLC et al

Filing 228

ORDER Granting 227 Stipulation for Extension of Time re 226 Motion for Protective Order (First Request). Responses due by 9/8/2017. Signed by Magistrate Judge Carl W. Hoffman on 8/22/17. (Copies have been distributed pursuant to the NEF - MR)

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1 2 3 4 5 6 7 8 9 Eckley M. Keach, Esq. Nevada Bar No. 1154 ECKLEY M. KEACH, CHTD. 521 South Third Street Las Vegas, NV 89101 (702) 685-6111 Robert E. Murdock, Esq. Nevada Bar No. 4013 MURDOCK & ASSOCIATES, CHTD. 521 South Third Street Las Vegas, NV 89101 (702) 685-6111 Attorneys for Plaintiffs 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 14 15 16 17 JENNIFER KWASNIEWSKI, individually and as Special Administrator of the ESTATE OF Case No. 2:12-cv-00515-GMN-CWH ANDREW A. KWASNIEWSKI; TAYLOR L. KWASNIEWSKI; and DYLAN A. KWASNIEWSKI, a minor, by and through Jennifer Kwasniewski, his mother and guardian, STIPULATION FOR EXTENSION OF TIME TO FILE PLAINTIFFS’ RESPONSE TO DEFENDANTS MOTION FOR Plaintiffs, PROTECTIVE ORDER /DOCKET 226/ 18 19 20 21 22 23 /First Request/ vs. SANOFI-AVENTIS U.S. LLC, a Delaware limited liability company; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive, Defendants. 24 25 IT IS HEREBY STIPULATED by and between Plaintiffs Jennifer Kwasniewski, 26 individually and as Special Administrator of the Estate Of Andrew A. Kwasniewski; Taylor L. 27 Kwasniewski; and Dylan A. Kwasniewski, a minor, by and through Jennifer Kwasniewski, his 28 mother and guardian, by and through their attorneys of record Murdock & Associates, Chtd. and 1 1 Eckley M. Keach, Chtd., and Defendant SANOFI-AVENTIS U.S. LLC, by and through its 2 attorneys of record Morris Law Group and Shook, Hardy & Bacon, LLP, that Plaintiffs shall have 3 until Friday, September 8, 2017, to file their Response to Defendant Sanofi-Aventis, U.S., LLC’s 4 5 Motion for Protective Order (Docket 226). Currently, Plaintiffs’ Response is due on August 28, 6 2017. The reason for the requested extension is that Counsel for Plaintiffs (Mr. Murdock) was out 7 of town from 8/14/17 through 8/18/17 taking FRCP 30(B)6 depositions in New Jersey, and will be 8 out of town from 8/21/17 through 8/28/17 (taking son to College at Columbia University in New 9 York). He also will be out of town in Cleveland, Ohio from 9/1/17 through 9/4/17 attending a 10 11 wedding. This is the First Request for an extension. 12 IT IS SO STIPULATED. 13 Dated this 21st day of August, 2017. 14 15 16 17 18 19 MURDOCK & ASSOCIATES, CHTD. ECKLEY M. KEACH, CHTD. MORRIS LAW GROUP /s/ Rosa Solis-Rainey Steve Morris, Esq. Rosa Solis-Rainey, Esq. 411 E. Bonneville Ave., Ste. 360 Las Vegas, NV 89101 /s/ Robert E. Murdock Robert E. Murdock, Esq. Eckley M. Keach, Esq. 521 S. Third Street Las Vegas, NV 89101 Attorneys for Plaintiffs SHOOK HARDY BACON, LLP Jon Andrew Strongman, Esq.(pro hac vice) Eric Swan, Esq. (pro hac vice) Harvey L Kaplan, Esq. (pro hac vice) 2555 Grand Blvd Kansas City, MO 64108 Attorney for Defendant Sanofi-Aventis US, LLC 20 21 22 23 24 ORDER 25 26 August 22 IT IS SO ORDERED this ______ day of ________________, 2017. 27 28 ____________________________________ UNITED STATES MAGISTRATE JUDGE 2

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