Carter v. Rent-A-Center, Inc.

Filing 13

ORDER granting 12 Stipulation to extend deadlines to respond to 7 Motion to Dismiss, 8 Motion to Strike, 9 Motion to Compel to June 1, 2015. Signed by Chief Judge Gloria M. Navarro on 5/18/2015. (Copies have been distributed pursuant to the NEF - DKJ)

David H. Krieger, Esq.
NV Bar No. 9086
HAINES & KRIEGER, LLC
8985 S. Eastern Avenue, Suite 130
Henderson, Nevada 89123
Phone: [phone]
FAX: [phone]
[e-mail]
Danny J. Horen, Esq.
NV Bar No. 13153
Kazerouni Law Group, APC
7854 W. Sahara Avenue
Las Vegas, NV 89117
Telephone: [phone]x7
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
CHAD CARTER,
INDIVIDUALLY AND ON
BEHALF OF ALL OTHERS
SIMILARLY SITUATED,
Plaintiff,
v.
RENT-A-CENTER, INC.,
Defendants.

Case No.: 2:15-cv-00178-GMN-CWH
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PLAINTIFF TO RESPOND TO
DEFENDANT’S MOTION TO
DISMISS; MOTION TO STRIKE
CLASS ALLEGATIONS; AND
MOTION TO COMPEL
ARBITRATION
[FIRST REQUEST]

Plaintiff, CHAD CARTER (“Plaintiff”), and Defendant, RENT-ACENTER, INC. (“Defendant”), hereby submit the following Stipulation to Extend
Time for Plaintiff to Respond to Defendant’s Motion to Dismiss. The current
deadline is set for May 18, 2015.
1. Plaintiff’s Complaint was filed on January 30, 2015.
2. Defendant concurrently filed three motions (Motion to Dismiss [Dkt. No. 7],
Motion to Compel Arbitration [Dkt. No. 9], Motion to Strike Class
Allegations [Dkt. No. 8]) on May 1, 2015.
3. Each Motion is substantially similar to the next.
4. The parties have agreed to an extension of time of 14 days, up to and
including June 1, 2015 for Plaintiff to respond to Defendant’s Motions To
Dismiss, Compel Arbitration, and Strike Class Allegations.
5. This request is not made for purposes of delay, but rather to allow Plaintiff
the opportunity to fully brief each challenge.
The parties therefore respectfully request this Court enter an order granting an
extension of time of 14 days, up to and including June 1, 2015, for Plaintiff to
respond to Defendant’s Motion to Dismiss; Motion to Strike Class Allegations; and
Motion to Compel Arbitration.
DATED: May 18, 2015
LITTLER MENDELSON

KAZEROUNI LAW GROUP, APC

/s/ Roger L. Grandgenett, II__
Roger L. Grandgenett, II, Esq.
3960 Howard Hughes Pkwy, Suite 100
Las Vegas, NV 89169
[e-mail]
Attorneys for Defendant

/S/ DANNY J. HOREN__________
DANNY J. HOREN, ESQ
7854 W. Sahara Avenue
Las Vegas, NV 89117
[e-mail]
Attorneys for Plaintiff

IT IS SO ORDERED:
Plaintiff shall have 14 days, up to and including June 1, 2015, to respond to
Defendant’s Motion to Dismiss; Motion to Strike Class Allegations; and Motion to
Compel Arbitration.
Dated this 18th day of May,
_____________________ 2015.
CARL W. HOFFMAN
UNITED STATES MAGISTRATE JUDGE

DATED: ____________________

___________________________
Gloria M. Navarro, Chief Judge
United States District Court

SIGNATURE CERTIFICATION
Pursuant to Section 2(f)(4) of the Electronic Filing Administrative Policies
and Procedures Manual, I hereby certify that the content of this document is
acceptable to counsel for Defendant, and that I have obtained their authorization to
affix their electronic signature to this document.

Dated: May 15, 2015

KAZEROUNI LAW GROUP
By: /s/ Danny Horen
DANNY HOREN, ESQ.
ATTORNEY FOR PLAINTIFF