Wright-Bolton v. Andress-Tobiasson et al

Filing 31

ORDER Granting 30 Stipulation to Extend Time to Respond to 29 Motion to Strike. Response due by 9/2/2015. Signed by Judge Andrew P. Gordon on 9/1/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01612-APG-PAL Document 30 Filed 08/28/15 Page 1 of 2

1 CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
2 C. J. POTTER, IV, ESQ.
Nevada Bar No. 13225
3 POTTER LAW OFFICES
1125 Shadow Lane
4 Las Vegas, NV 89102
Ph: [phone]
5 Fax: [phone]
[e-mail]
6 Attorneys for Plaintiff
7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
VIVIAN WRIGHT-BOLTON;

CASE NO.: 2:14-cv-01612-APG-PAL

11
Plaintiff,
12 v.
13 MELANIE ANDRESS-TOBIASSON,
individually; THE ESTATE OF JENNIFER
14 BOLTON deceased; KOCKA & BOLTON,
LLC, a Nevada Limited Liability Company;
15
Defendants.
16 _______________________________________/
17

STIPULATION AND ORDER TO EXTEND PLAINTIFF’S RESPONSE TO

18

DEFENDANT ANDRESS-TOBIASSON’S MOTION TO STRIKE

19

IT IS HEREBY STIPULATED AND AGREED, by and between the Plaintiff, VIVIAN

20 WRIGHT-BOLTON, by and through her counsel, CAL J. POTTER, III, ESQ. and C. J.
21 POTTER, IV, ESQ. of POTTER LAW OFFICES and Defendant, MELANIE ANDRESS22 TOBIASSON, by and through her counsel WALTER R. CANNON, ESQ. and THOMAS D.
23 DILLARD, JR, ESQ. of OLSON CANNON GORMLEY & STOBERSKI that the date for
24 Plaintiff to file her Response to Defendant Andress-Tobiasson’s Motion to Strike [doc. 29]
25 currently due Friday, August 28, 2015 be extended five (5) days up to and including
26 Wednesday, September 2, 2015.
27

Plaintiff submits that good cause exists for this extension as Plaintiff’s counsel has been

28 unable to complete the Response due to numerous court appearances, multiple depositions,

Case 2:14-cv-01612-APG-PAL Document 30 Filed 08/28/15 Page 2 of 2

1 multiple mediations and court-ordered settlement conferences, and other deadlines, including
2 but not limited to Ninth Circuit and Nevada Supreme Court appeal briefs. Based upon the
3 foregoing, the parties request that this Court order the time for the Plaintiff to file her Reply to
4 Wednesday, September 2, 2015.
5

This is the first request for enlargement of time is made in good faith and not for the

6 purposes of delay.
7

DATED this 28th day of August, 2015.

DATED this 28th day of August, 2015.

8

POTTER LAW OFFICES

OLSON, CANNON, GORMLEY,
ANGULO & STOBERSKI

9

By /s/ C. J. Potter, IV, Esq.
CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
C. J. POTTER, IV. ESQ.
Nevada Bar No. 13225
1125 Shadow Lane
Las Vegas, NV 89102
Attorneys for Plaintiff

10
11
12
13

By /s/ Thomas D. Dillard, Jr., Esq.
WALTER R. CANNON, ESQ.
Nevada Bar No. 1505
THOMAS D. DILLARD, JR., ESQ.
Nevada Bar No. 6270
9950 W. Cheyenne Avenue
Las Vegas, NV 89129
Attorney for Defendant Melanie
Andress-Tobiasson

14
15
16
17
18
19
20

ORDER
It is so Ordered.
September 1, 2015
__________________
DATED

______________________________________
U.S. DISTRICT COURT JUDGE

21
22
23
24
25
26
27
28
2