Rodriguez v. AT&T Services, Inc.

Filing 24

ORDER Granting 23 Stipulation for an Extension of Time to Reply to 11 Motion to Compel. Signed by Chief Judge Gloria M. Navarro on 1/23/2015. (Copies have been distributed pursuant to the NEF - SLR)

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1 2 3 4 5 6 7 8 9 10 Leslie Bryan Hart (SBN # 4932) FENNEMORE CRAIG, P.C. 300 East Second Street, Suite 1510 Reno, Nevada 89501 T: 775.788.2228 F: 775.788.2229 lhart@fclaw.com (Admitted Pro Hac Vice) Archis A. Parasharami, Esq. James F. Tierney, Esq. MAYER BROWN LLP 1999 K Street NW Washington, DC 20006 Tel: 202-263-3000 Fax: 202-263-3300 aparasharami@mayerbrown.com jtierney@mayerbrown.com Attorneys for Defendant AT&T Services, Inc. 11 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 12 13 14 JUAN RODRIGUEZ, on behalf of himself and all others similarly situated, Plaintiff, 15 16 17 vs. AT&T SERVICES, INC. , Case No. 2:14-cv-01537-GMN AMENDED STIPULATION AND AMENDED STIPULATION OF ORDER FOR OF TIME FOR TIME EXTENSION EXTENSION OF DEFENDANT TO FILE ITS REPLY FOR DEFENDANT TO FILE ITS BRIEF IN SUPPORT OF ITS MOTION REPLY BRIEF IN SUPPORT OF ITS TO COMPEL ARBITRATION MOTION TO COMPEL ARBITRATION (THIRD REQUEST) Defendant. 18 19 Defendant AT&T Services, Inc. (“AT&T”) and Plaintiff Juan Rodriguez respectfully 20 submit this amended stipulation under Local Rules 6-1 and 7-1 for an extension of time for 21 Defendant to file its reply brief in support of its motion to compel arbitration. 22 1. AT&T was served in this action on September 25, 2014. 2. The Court granted the parties’ stipulation to extend the time to answer or 23 24 otherwise respond to the Complaint to November 17, 2014. Dkt. # 6. 25 3. AT&T filed its Motion to Compel Arbitration on November 17, 2014. Dkt. # 11. 4. The Court granted the parties’ stipulation to extend the time for Rodriguez to file 26 27 28 FENNEMORE CRAIG, P.C. 300 EAST SECOND STREET SUITE 1510 RENO, NV 89501 (775) 788-2228 AMENDED STIPULATION OF EXTENSION OF TIME (THIRD REQUEST) Page 1 of 3 1 his response brief to December 18, 2014, and to extend the time for AT&T to file its reply brief 2 to January 9, 2015. Dkt. # 16. 3 5. Rodriguez filed his response brief on December 18, 2014. Dkt. # 17. 4 6. The parties agreed to extend by seven days the time for AT&T to file its reply 5 brief, in light of commitments that arose since the parties’ last stipulation. 6 7 7. sought in good faith and not for purposes of undue delay or unfair prejudice. 8 9 This stipulated extension, which is AT&T’s third such request in this case, is 8. AT&T filed its reply brief in support of its motion to compel arbitration on January 16, 2015. Dkt. # 21. 10 9. On January 21, 2015, the Court ordered the parties to file an Amended Stipulation 11 clarifying the requested relief. Dkt. # 22. The parties hereby file this Amended Stipulation to 12 clarify that AT&T’s initial response to the Complaint was its motion to compel arbitration, and 13 that they are requesting in this Amended Stipulation that the time for AT&T to file its reply brief 14 in support of its motion to compel arbitration be extended to January 16, 2015, and AT&T has 15 now filed the reply brief. 16 10. 17 WHEREFORE, the parties stipulate and jointly request that this Court grant the following 18 relief:  19 20 AT&T shall have an extension of time to and including January 16, 2015, to file its reply brief in support of its motion to compel arbitration; 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 FENNEMORE CRAIG, P.C. 300 EAST SECOND STREET SUITE 1510 RENO, NV 89501 (775) 788-2228 The parties apologize for any confusion and inconvenience to the Court. AMENDED STIPULATION OF EXTENSION OF TIME (THIRD REQUEST) Page 2 of 3  1 Such other and further relief as this Court deems just and proper. Dated this 22nd day of January, 2015. 2 3 4 KAZEROUNI LAW GROUP, APC FENNEMORE CRAIG, P.C. By: By: 5 6 7 8 9 /s/ Danny J. Horen Danny J. Horen (SBN # 13153) danny@kazlg.com 7854 W. Sahara Avenue Las Vegas, Nevada 89117 T: 800.400.6808 F: 800.520.5523 Attorney for Plaintiff /s/ Leslie Bryan Hart Leslie Bryan Hart (SBN # 4932) lhart@fclaw.com 300 East Second Street, Suite 1510 Reno, Nevada 89501 T: 775.788.2228 F: 775.788.2229 and 10 Archis A. Parasharami (pro hac vice) aparasharami@mayerbrown.com James F. Tierney (pro hac vice) jtierney@mayerbrown.com MAYER BROWN LLP 1999 K Street NW Washington, DC 20006 T: 202.263.3000 F: 202.263.3300 Attorneys for Defendant 11 12 13 14 15 16 ORDER 17 18 19 20 IT IS SO ORDERED: _______________________________________ UNITEDSO ORDERED. COURT JUDGE IT IS STATES DISTRICT DATED: ____________________ 21 22 23 24 _____________________________ Gloria M. Navarro, Chief Judge United States District Court DATED: 01/23/2015 25 26 27 28 FENNEMORE CRAIG, P.C. 300 EAST SECOND STREET SUITE 1510 RENO, NV 89501 (775) 788-2228 AMENDED STIPULATION OF EXTENSION OF TIME (THIRD REQUEST) Page 3 of 3

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