Verma et al v. Regional Transportation Commision of Southern Nevada et al

Filing 18

ORDER Granting 17 Stipulation to Extend Time (First Request) to File a Response to 13 MOTION to Dismiss 1 Complaint. Plaintiffs' Responses due by 11/11/2016. Signed by Judge Jennifer A. Dorsey on 10/21/2016. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-02037-JAD-NJK Document 17 Filed 10/20/16 Page 1 of 2

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THE THATER LAW GROUP, P.C.
M. Lani Esteban-Trinidad
Nevada Bar No. 006967
6390 W. Cheyenne Ave., Ste. A
Las Vegas, Nevada 89108
Telephone: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorney for Plaintiffs
MANUEL VERMA & DUANE USHIJIMA

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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MANUEL VERMA, an individual, DUANE
USHIJIMA, an individual,

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Plaintiffs,
vs.

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Case No. 2:16-cv-2037-JAD-NJK
Case No.: 2:16-cv-01922-RFB-CWH

KEOLIS TRANSIT AMERICA, LLC; DOES 1
through 10 inclusive; ROES
CORPORATIONS/ENTITIES 1 through 10
inclusive; and REGIONAL
TRANSPORTATIONC OMMISSION OF
SOUTHERN NEVADA; DOES 1 through 10
inclusive; ROES CORPORATIONS/ENTITIES
1 through 10 inclusive,

STIPULATION AND ORDER TO EXTEND
TIME FOR PLAINTIFFS MANUEL VERMA
AND DUANE USHIJIMA TO FILE A
RESPONSIVE PLEADING TO DEFENDANTS’
MOTION TO DISMISS PLAINTIFF’S
COMPLAINT
(FIRST REQUEST)

Defendants.

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Plaintiffs MANUEL VERMA and DUANE USHIJIMA (“Plaintiffs”), by and through their

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counsel of record, The Thater Law Group, P.C. and Defendants KEOLIS TRANSIT AMERICA, LLC

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(“Keolis”) and REGIONAL TRANSPORTATION COMMISSION OF SOUTHERN NEVADA

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(“RTC”), by and through their respective counsel Jackson Lewis, P.C., hereby stipulate and agree to

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extend the time for Plaintiffs to file a responsive pleading to Defendants Keolis and RTC’s Motion to

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Dismiss from October 28, 2016 up to and including November 11, 2016.

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Case 2:16-cv-02037-JAD-NJK Document 17 Filed 10/20/16 Page 2 of 2

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The parties seek the requested extension because the current date for Plaintiff to respond to the

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pending defense Motion falls on Friday, October 28, 2016, which is Nevada Day, with Plaintiff’s

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counsel’s staff off from work in observance of the state holiday and given Plaintiff’s counsel’s multiple

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coinciding deadlines in pending State Court cases during that shortened work week, Plaintiff’s counsel
requires the additional time to respond to defense Motions.

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This stipulation and order is sought in good faith and not for the purpose of delay.

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DATED this 20th day of October, 2016.

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THE THATER LAW GROUP, P.C.

JACKSON LEWIS, P.C.

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BY:/s/ M. Lani Esteban-Trinidad
M. Lani Esteban-Trinidad, Esq.
Nevada Bar No. 6967
6390 West Cheyenne Ave., Suite A
Las Vegas, NV 89108
Attorney for Plaintiffs

BY:/s/ Paul Trimmer
Paul Trimmer, Esq. NV Bar No. 9291
Dione C. Wrenn, Esq. NV Bar No. 13285
3800 Howard Hughes Parkway, Suite 600
Las Vegas, NV 89169
Attorneys for Defendants

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ORDER
IT IS SO ORDERED.

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_____________________________________
U.S. District/Magistrate Judge JUDGE
UNITED STATES DISTRICT
Dated: October 21, 2016.
Dated:__________________________

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