Stahl v. Target Corporation
Filing
23
ORDER Granting 21 Unopposed Motion to Extend Time to Respond re 20 Motion for Summary Judgment. Responses due by 10/19/2016. Signed by Magistrate Judge George Foley, Jr on 10/18/16. (Copies have been distributed pursuant to the NEF - MMM)
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 1 of 6
1
2
3
4
5
6
APPL
WILLIAM R. KILLIP JR., ESQ.
Nevada Bar No. 3660
NETTLES LAW FIRM
1389 Galleria Drive, Suite 200
Henderson, Nevada 89014
Telephone: (702) 434-8282
Facsimile: (702) 434-1488
bill@nettleslawfirm.com
Attorneys for Plaintiff
7
Lfl1iUI]1WUJ]KttitIIZEI1$HU
8
Ii]
9
L41S1
CASE NO. 2:15-CV-01681-RFB-GWF
10
11
Plaintiff,
12
ci
oo
Z r"i
’
c
-
5
O
-.
00
16
VS.
TARGET CORPORATION; DOE
INDIVIDUALS 1 through 10; ROE
CORPORATIONS 11 through 20;
and ABC LIMITED LIABILITY
COMPANIES 21 through 30;
17
Defendants.
18
19
20
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
21
(First Request)
22
23
24
25
26
27
28
Plaintiff Deanna Stahl ("Ms. Stahl") by and through her attorney William R. Killip, Jr.
Esq., of the Nettles Law Firm, hereby moves this Court, pursuant to LR IA 6-1 and LR IA 6-1 ol
the U.S. District Court, District of Nevada Local Rules of Practice, for an extension of time to fih
Plaintiffs Opposition to Defendant’s Motion for Summary Judgment. Defendant’s Motion
Summary Judgment was filed on September 23, 2016. This motion is made and based on all
pleadings and papers on file herein and the following Points and Authorities.
I/I
51
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 2 of 6
ri I iiva i
1
s& lii V I
I
ri lull
II
flIjI
2
3
4
5
6
7
8
9
10
11
12
STATE OF NEVADA
COUNTY OF CLARK
1.
I am the attorney for Deanna Stahl, the plaintiff herein. I have personal knowledge of th
facts set forth in this affidavit. If called upon to do so, I could competently testify as to the matte]
stated herein.
2.
On October 17, 2016, my office spoke with Defendant’s counsel Douglas M. Rowan, Esq
regarding an extension of time to file Plaintiffs Opposition to Defendant’s Motion for Summar)
Judgment.
3.
The parties agreed upon an extension to October 19, 2016 for the filing of Plaintiff
Opposition.
4.
j > ,.
)
) ss:
)
Due to the lateness of the hour, Plaintiff files an unopposed Motion to extend the time tc
file Plaintiffs Opposition to October 19, 2016.
i
;-
oo
16
5.
I declare under penalty of perjury under the laws of the State of Nevada that the
foregoing is true and correct.
.17
18
19
20
21
22
23
24
25
26
27
28
SUBSCRIBED AND SWORN to before
me tls L( dayo.f October, 2016.
LIC
r
NOTARY p
STATE OF NEVADAWLWry CF CLAW
MY App
"M UP MAY a 2020
No: OO41i
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 3 of 6
UI] Iii IVWthi :isui UI 3
1
2
3
4
This arises from a personal injury incident while Plaintiff was shopping at the Target ston
5
located at 4100 Blue Diamond Road in Las Vegas, Nevada ("the Premises"). On August 30, 2013
6
Plaintiff was purchasing some plastic containers at the cash register when she noticed the item
7
she intended to purchase were broken. Due to the length of time Defendant’s employees wer
8
taking to bring new containers to the register, Plaintiff informed the cashier she would go get ne
9
containers to purchase herself. While Plaintiff was walking towards the isle where the container
10
were located, she slipped and fell on a puddle of clear liquid located on the floor in the area of th
_11
greeting cards. Plaintiff sustained serious injuries as a result.
12
On September 23, 2016, Defendant filed its Motion for Summary Judgment on the ground
13
that there is insufficient evidence upon which Plaintiff can established a cause of action o
4
Summary Judgment is due on October 17, 2016.
cQ
-
negligence against Target as a matter of law. Plaintiffs Opposition to Defendant’s Motion
-
OO
oo
cq
Cq
r-
16
17
T
18
Plaintiffs seeks a two day extension of time to file her Opposition to Defendant’s
19
for Summary Judgment. On October 17, 2016, Plaintiffs counsel’s office spoke with defens
20
counsel Douglas M. Rowan, Esq. by telephone regarding an extension to file Plaintiff!
21
Opposition. The parties were in agreement to extend Plaintiffs filing date to October 19, 2016
22
Due to the lateness of the hour, Plaintiff files this unopposed motion for an extension to fib
23
Plaintiffs Opposition to Defendant’s Motion for Summary Judgment by October 19, 2016.
24
Affidavit of William R. Killip, Jr., Esq., attached hereto.
25
26
27
III
28
III
-3-
Se
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 4 of 6
III.
I
2
3
4
5
CONCLUSION
,
Plaintiff respectfully request that this Honorable Court grant an extension of time to
Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment.
DATED this
day of October, 2016.
NETTLES LAW FIRM
6
7
8
By:
9
10
11
CD
12
C,DC"
o’, >>
14
WILLIAM R. KILLIP .JR...ESQ.
Nevada Bar No. 3660
1389 Galleria Drive, Suite 200
Henderson, Nevada 89014
Telephone: (702) 434-8282
Facsimile: (702) 434-1488
kffl,nettlesIawfirrn.com
Attorney for Plaintiff
15
16
IT IS SO ORDERED:
17
r-
18
19
UNITED STATES DISTRICT COURT CLERK
UNITED STATES MAGISTRATE JUDGE
20
DATED: October 18, 2016
21
22
23
24
25
26
27
28
In
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 5 of 6
1
CERTI ? WATE OF SERVICE
2
3
4
I hereby certify that on the
of the above and foregoing Unopposed Motion to Extend Time to
Defendant’s Motion for Summary Judgment
5
6
7
8
9
10
12
Facsimile: (702) 727-1401
Kym Samuel Cushing, Esq.
Douglas M. Roman, Esq.
WILSON, ELSER, MOSKOWITZ,
EDELMAN DICKER LLP
300 S. Fourth St., 11 fl.
Las Vegas, Nevada 89101
Attorney for Defendant
[
]
Hand Delivery
oc
’k
[
Facsimile Transmission
z
[t]
U.S. Mail, Postage Prepaid
[
]
Certified Mail, Receipt No.
[
]
Return Receipt Requested
15
16
17
18
19
20
21
22
23
24
25
26
27
28
October, 2016, that I served true and correct copie
File Plaintiffs Opposition t
on all interested parties, addressed as follows:
Case 2:15-cv-01681-RFB-GWF Document 21 Filed 10/17/16 Page 6 of 6
Total Time: 000119
Job No.: 115330
Page: 005
Complete
Document:
doc20161017182157
It
UNITED STATES DISTRICT COURT
DISTRICT OF NVADA
No.
Date and Time Destination
Times
Type
001
10/17/16 18:22 7027271401
00119" FAX
Result
Resolution/ECM
OK
200x100 Normal/On
[ OHYOZ05300 ]
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?