Kim v. United States of America

Filing 12

ORDER Granting 11 Stipulation re 10 MOTION to Dismiss. Responses due by 9/14/2016. Signed by Judge Andrew P. Gordon on 8/15/2016. (Copies have been distributed pursuant to the NEF - TR)

Case 2:16-cv-00778-APG-CWH Document 11 Filed 08/15/16 Page 1 of 3

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PAUL S. PADDA, ESQ.
Nevada Bar No. 10417
[e-mail]
PAUL PADDA LAW, PLLC
4240 W. Flamingo Rd., Suite 220
Las Vegas, Nevada 89103
Telephone: [phone]
Facsimile: 702.366.1940

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KATHLEEN BLISS, ESQ.
Nevada Bar No. 7606
[e-mail]
JASON HICKS, ESQ.
Nevada Bar No. 13149
[e-mail]
KATHLEEN BLISS LAW PLLC
400 S. 4th St., Suite 500
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: 702.793.4001

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400 S. 4TH ST., SUITE 500
LAS VEGAS, NEVADA 89101
TEL[phone] FAX: [phone]

KATHLEEN BLISS LAW PLLC

Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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THOMAS KIM,

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CASE NO.: 2:16-cv-00778-APG-CWH
Plaintiff;

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vs.

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UNITED STATES OF AMERICA,

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STIPULATION AND PROPOSED
ORDER FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT’S MOTION
TO DISMISS

Defendant.

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Pursuant to the Local Rules of Civil Practice, the parties stipulate to provide Plaintiff an

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additional thirty (30) days, up to and including September 14, 2016, to respond to Defendant’s

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motion to dismiss (ECF No. 10). In support of this stipulation, the parties rely upon the following:

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1. Plaintiff’s response to the pending motion to dismiss was originally due on August 15,
2016.1

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2. Due to other case commitments, travel, and scheduling issues, counsel for Plaintiff have

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not had sufficient time to oppose the United States’ motion.

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3. Prior to the due date, Plaintiff sought a thirty day extension, which the government does

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The August 13, 2016, due date generated by CM/ECF fell on a Saturday.

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Case 2:16-cv-00778-APG-CWH Document 11 Filed 08/15/16 Page 2 of 3

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not oppose.
4. In light of the foregoing, the parties agree that Plaintiff shall have an additional thirty
(30) days, up to and including September 14, 2016, to file his opposing to the pending
motion to dismiss.
5. This stipulation is entered into in good faith and not for purposes of delay.
Dated this 15th day of August 2016.

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400 S. 4TH ST., SUITE 500
LAS VEGAS, NEVADA 89101
TEL[phone] FAX: [phone]

KATHLEEN BLISS LAW PLLC

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/s/ Paul S. Padda_____________
PAUL S. PADDA, ESQ.
PAUL PADDA LAW, PLLC
4240 W. Flamingo Rd., Suite 220
Las Vegas, NV 89103

/s/ Katherine Foss______________
KATHERINE FOSS, ESQ.
COLE HERNANDEZ, ESQ.
United States Attorney’s Office
District of Arizona
405 W. Congress St., Suite 4800
Tucson, AZ 85701

KATHLEEN BLISS, ESQ.
JASON HICKS, ESQ.
KATHLEEN BLISS LAW PLLC
400 S. 4th St., Suite 500
Las Vegas, NV 89101

Attorneys for Defendant

Attorneys for Plaintiff

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ORDER
Based upon the stipulation of the parties, and good cause appearing, it is hereby

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ORDERED that the stipulation for an extension of time is approved. Plaintiff shall file his

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opposition to Defendant’s motion to dismiss on or before September 14, 2016.

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Dated:_________________
Dated: August 15, 2016.

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___________________________________

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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