Koopman v. Kohl's Department Stores, Inc.

Filing 15

ORDER Granting 14 Stipulation to Extend Time to Respond to 9 Motion to Dismiss. Response due by 8/12/2015. Signed by Judge Miranda M. Du on 7/13/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:15-cv-00462-MMD-CWH Document 14 Filed 07/10/15 Page 1 of 4

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
CHRISTINE KOOPMAN
Plaintiff,
v.
KOHL’S DEPARTMENT
STORES, INC.,
Defendants.

Stipulation

Case No.: 2:15-cv-00462-MMD-CWH
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PLAINTIFF TO RESPOND TO
DEFENDANT’S MOTION TO
DISMISS
[SECOND REQUEST]

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Case 2:15-cv-00462-MMD-CWH Document 14 Filed 07/10/15 Page 2 of 4

Plaintiff, CHRISTINE KOOPMAN (“Plaintiff”), and Defendant, KOHL’S
DEPARTMENT STORES, 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 July 13, 2015.
1. Plaintiff’s Complaint was filed on March 12, 2015. [Dkt. No. 1]
2. Defendant filed its Motion to Dismiss [Dkt. No. 9] on June 12, 2015.
3. The parties are engaged in good faith settlement discussion. Plaintiff and
Defendant have agreed to an extension of time of 30 days, up to and
including August 12, 2015 for Plaintiff to respond to Defendant’s Motion To
Dismiss.
4. This request is not made for purposes of delay, but rather to allow the parties
to explore settlement.
The parties therefore respectfully request this Court enter an order granting an
extension of time of 30 days, up to and including August 12, 2015, for Plaintiff to
respond to Defendant’s Motion to Dismiss.
DATED: July 10, 2015
PISANELLI BICE

KAZEROUNI LAW GROUP, APC

/s/ Jordan Smith____________
Jordan Smith, Esq.
400 S. 7th St., Ste. 300
Las Vegas, NV 89101
[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

Stipulation

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Case 2:15-cv-00462-MMD-CWH Document 14 Filed 07/10/15 Page 3 of 4

IT IS SO ORDERED:
Plaintiff shall have 30 days, up to and including August 12, 2015, to respond
to Defendant’s Motion to Dismiss.
_____________________
UNITED STATES DISTRICT COURT JUDGE
July 13, 2015
DATED: ____________________

Stipulation

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Case 2:15-cv-00462-MMD-CWH Document 14 Filed 07/10/15 Page 4 of 4

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: July 10, 2015

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

Stipulation

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