Douglas v. Dreamdealers USA, LLC et al

Filing 55

ORDER Granting 52 First Stipulation for Extension of Time Re: 50 Motion to Compel. Plaintiff's Responses due by 1/23/2020. Signed by Magistrate Judge Brenda Weksler on 1/22/2020. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02134-APG-BNW Document 52 Filed 01/21/20 Page 1 of 2

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DUSTIN L. CLARK
Nevada Bar No. 10548
E-mail: [e-mail]
HOLLEY DRIGGS WALCH
FINE PUZEY STEIN & THOMPSON
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Edward B. Douglas

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
EDWARD B. DOUGLAS, an individual,
Plaintiff,

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v.
DREAMDEALERS USA, LLC d/b/a Exotics
Racing, a Nevada limited liability company,
DAVID PERISSET, an individual, and
ROMAIN THIEVIN, an individual,

Case No. 2:17-cv-02134-APG-BNW
STIPULATION AND PROPOSED
ORDER TO EXTEND TIME TO
RESPOND TO MOTION TO COMPEL
DISCOVERY [ECF No. 50]
(First Request)

Defendants.

Plaintiff, EDWARD B. DOUGLAS (“Plaintiff”), and Defendants, DREAMDEALERS
USA, LLC, DAVID PERISSET, and ROMAN THIEVIN (collectively “Defendants”), hereby
agree and stipulate to extend by two days the time for Plaintiff to respond to Defendants’ Motion
to Compel Discovery, ECF No. 50, from the current deadline of January 21, 2020 up to and
including January 23, 2020. This is the first request to extend the time for Plaintiff to respond to
Defendants’ Motion to Compel Discovery, which was filed on January 7, 2020.
Good cause exists to grant this stipulation and extend the response deadline by two days.
In particular, Plaintiff has been out of state attending medical appointments with his wife as she
seeks treatment related to breast cancer and a traumatic brain injury. Plaintiff has also been out of
state taking care of an elderly family member facing significant medical issues and requiring end-

Case 2:17-cv-02134-APG-BNW Document 52 Filed 01/21/20 Page 2 of 2

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of-life care. Accordingly, the requested extension is sought in good faith and not for purposes of

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undue delay.

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DATED: January 21, 2020

DATED: January 21, 2020

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Respectfully submitted,

Respectfully submitted,

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CLARK LAW COUNSEL PLLC

LITTLER MENDELSON, P.C.

/s/ Dustin L. Clark
Dustin L. Clark
Attorney for Plaintiff

/s/ Marcus B. Smith
Wendy M. Krincek
Marcus B. Smith
Attorney for Defendants

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IT IS SO ORDERED.

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______________________________________
UNITED STATES MAGISTRATE JUDGE

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1/22/2020
DATED:_______________________________

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