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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Eckley M. Keach, Esq.
Nevada Bar No. 1154
ECKLEY M. KEACH, CHTD.
521 South Third Street
Las Vegas, NV 89101
[phone]
Robert E. Murdock, Esq.
Nevada Bar No. 4013
MURDOCK & ASSOCIATES, CHTD.
521 South Third Street
Las Vegas, NV 89101
[phone]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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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/

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/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.

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IT IS HEREBY STIPULATED by and between Plaintiffs Jennifer Kwasniewski,

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individually and as Special Administrator of the Estate Of Andrew A. Kwasniewski; Taylor L.

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Kwasniewski; and Dylan A. Kwasniewski, a minor, by and through Jennifer Kwasniewski, his

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mother and guardian, by and through their attorneys of record Murdock & Associates, Chtd. and
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Eckley M. Keach, Chtd., and Defendant SANOFI-AVENTIS U.S. LLC, by and through its

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attorneys of record Morris Law Group and Shook, Hardy & Bacon, LLP, that Plaintiffs shall have

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until Friday, September 8, 2017, to file their Response to Defendant Sanofi-Aventis, U.S., LLC’s

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Motion for Protective Order (Docket 226). Currently, Plaintiffs’ Response is due on August 28,

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2017. The reason for the requested extension is that Counsel for Plaintiffs (Mr. Murdock) was out

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of town from 8/14/17 through 8/18/17 taking FRCP 30(B)6 depositions in New Jersey, and will be

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out of town from 8/21/17 through 8/28/17 (taking son to College at Columbia University in New

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York). He also will be out of town in Cleveland, Ohio from 9/1/17 through 9/4/17 attending a

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wedding. This is the First Request for an extension.

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IT IS SO STIPULATED.

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Dated this 21st day of August, 2017.

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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

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ORDER

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August 22
IT IS SO ORDERED this ______ day of ________________, 2017.

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____________________________________
UNITED STATES MAGISTRATE JUDGE
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