Laird v. American Honda Finance Corp et al

Filing 5

ORDER Granting 4 Stipulation for Extension of Time. American Honda Finance Corp answer due 6/21/2017. Signed by Magistrate Judge Nancy J. Koppe on 6/9/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01383-JAD-NJK Document 4 Filed 06/08/17 Page 1 of 2

1
2
3
4
5

Chad C. Butterfield, Esq.
Nevada Bar No. 010532
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
[phone]; FAX [phone]
[e-mail]
Attorneys for Defendant
AMERICAN HONDA FINANCE CORPORATION

6
7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9
10

KAREN S. LAIRD,
Plaintiff,

11
12
13

Case No.: 2:17-CV-01383-JAD-NJK

v.
AMERICAN HONDA FINANCE CORP.;
EQUIFAX INFORMATION SERVICES, LLC,

STIPULATION AND [PROPOSED] ORDER
FOR EXTENSION OF TIME TO FILE
RESPONSIVE PLEADING TO PLAINTIFF’S
COMPLAINT
(First Request)

14

Defendants.

15
16

Defendant, AMERICAN HONDA FINANCE CORPORATION (hereinafter “AHFC”), by

17
and through its counsel of record, CHAD C. BUTTERFIELD, ESQ., of the law firm WILSON,
18
ELSER, MOSKOWITZ, EDELMAN & DICKER LLP, and Plaintiff, GREGORY P.
19
ROMBOLETTI, by and through his counsel of record, DAVID H. KRIEGER, ESQ. of the law firm
20
HAINES & KRIEGER, LLC hereby stipulate and agree to extend the deadline for filing a
21
responsive pleading to June 21, 2017.
22
This stipulation is submitted in compliance with LR IA 6-1. Good cause exists for the
23
requested extension, as counsel for AHFC has only recently been retained to represent AHFC in
24
this matter and has only recently obtained the relevant file materials and information necessary to
25
respond to the allegations set forth in the Complaint. Accordingly, the parties agree that the
26
requested extension furthers the interests of this litigation and is not being requested in bad faith or
27
to delay these proceedings unnecessarily.
28

1
1159201V.1

Case 2:17-cv-01383-JAD-NJK Document 4 Filed 06/08/17 Page 2 of 2

1

This is the parties’ first request for extension of the deadline. The parties' failure to file this

2

stipulation on or before June 7, 2017 (i.e., the original responsive pleading deadline) was the result

3

of a clerical error by counsel for AHFC's former legal assistant, who inadvertently failed to calendar

4

the deadline. Counsel for AHFC immediately contacted Plaintiff's counsel to request a stipulation

5

to extend the deadline upon realizing that the responsive pleading deadline had passed. Plaintiff's

6

counsel graciously agreed to the requested extension. Accordingly, the parties respectfully submit

7

that the failure to submit this stipulation on or before June 7, 2017 was the result of excusable

8

neglect.

9

DATED this 8th day of June, 2017.
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

10
11

/s/ Chad C. Butterfield
Chad C. Butterfield, Esq.
Nevada Bar No. 010532
300 South Fourth Street, 11th Floor
Las Vegas, NV 89101
Attorneys for Defendant Target Corporation

12
13
14
15

DATED this 8th day of June, 2017.
HAINES & KRIEGER, LLC

16

/s/ David H. Krieger
David H. Krieger, Esq.
Nevada Bar No. 9806
8985 S. Eastern Ave., Suite 350
Henderson, NV 89123
Attorney for Plaintiff Gregory Romboletti

17
18
19
20
21
22
23

ORDER
GOOD CAUSE SHOWN, IT IS SO ORDERED.

24
25

9th
June
Dated this _____ day of _____________, 2017.

26
27

________________________________________
UNITED STATES MAGISTRATE JUDGE

28

2
1159201V.1