Carson v. Target Corporation

Filing 11

ORDER Granting 10 Stipulation for Extension of Time (First Request) to File Reply to 6 Motion to Remand. The due date for the Reply is retroactively extended to 4:47 A.M. on 4/27/2017. Signed by Judge James C. Mahan on 5/1/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-00669-JCM-VCF Document 10 Filed 04/28/17 Page 1 of 2

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SANDY VAN, ESQ.
Nevada Bar No. 10785
VAN LAW FIRM
4170 S. Decatur Blvd.
Suite B-6
Las Vegas, Nevada 89103
[phone] Telephone
[phone] Facsimile
[e-mail] Email
Attorney for Plaintiff Angelina Carson
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
Fax [phone]

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Phone [phone]

4170 S. Decatur Blvd. Suite B6, Las Vegas, NV 89103

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ANGELINA CARSON, individually,
Plaintiff,
vs.

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TARGET CORPORATION, a foreign
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and ROE CORPORATIONS I - X, inclusive,
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Defendants.

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CASE NO. 2:17-cv-00669-JCM-VCF

STIPULATION AND PROPOSED ORDER
TO EXTEND DUE DATE FOR
PLAINTIFF’S REPLY TO DEFENDANT’S
OPPOSITION TO PLAINTIFF’S MOTION
TO REMAND
FIRST REQUEST

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Plaintiff ANGELINA CARSON (hereinafter “Plaintiff” or “CARSON”), by and through her

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attorney of record, SANDY VAN, ESQ. of VAN LAW FIRM and Defendant, TARGET

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CORPORTION dba TARGET, by and through its attorney of record DOUGLAS M. ROWAN,

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ESQ. of WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, hereby stipulate as
follows:
(1)

The due date for Plaintiffs’ Reply to Defendant’s Opposition to Plaintiff’s Motion to

Remand (ECF 6) was April 26, 2017.
(2)

The parties agree that the due date for the Reply to Opposition should be extended 4

hours and 47 minutes to 4:47 a.m. on April 27, 2017.
(3)

Counsel for Plaintiff had intermittent computer problems while getting the document

filed via ECF that caused the inability of Plaintiff’s Counsel to file the Reply to Defendant’s

Case 2:17-cv-00669-JCM-VCF Document 10 Filed 04/28/17 Page 2 of 2

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Opposition to Plaintiff’s Motion to Remand until 4:47 a.m. on April 27, 2017, which was 4 hours

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and 47 minutes late.
(4)

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Counsel for Defendant, has no objection to the filling being 4 hours and 47 minutes

late.
IT IS SO STIPULATED.
Dated this 28th day of April, 2017.

Dated this 28th day of April, 2017.

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VAN LAW FIRM

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

/s/ Sandy Van
SANDY VAN, ESQ.
Nevada Bar No. 10785
4170 S. Decatur Blvd., Suite B6
Las Vegas, NV 89103
[phone] Telephone
[phone] Facsimile
[e-mail] Email
Attorney for Plaintiff Angelina Carson

/s/ Douglas M. Rowan
DOUGLAS M. ROWAN, ESQ.
Nevada Bar No. 4736
300 South Fourth Street, 11th Floor
Las Vegas, NV 89101
[phone] Telephone
[phone] Facsimile
[e-mail] Email
Attorney for Defendant Target Corporation

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Fax [phone]

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Phone [phone]

4170 S. Decatur Blvd. Suite B6, Las Vegas, NV 89103

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ORDER

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Pursuant to the terms of the attached stipulation, the Court orders as follows:

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1. Good cause exists for the retroactive extension of the due date for Plaintiffs’ Reply to

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Defendant’s Opposition to Plaintiff’s Motion to Remand (ECF 6).

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2. The due date for the Reply is retroactively extended to 4:47 A.M. on April 27, 2017.

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IT IS SO ORDERED.

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________________________________________
UNITED STATES DISTRICT JUDGE

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May 1, 2017
DATED: _________________________

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