United States of America, ex rel et al v. Fife Dermatology PC et al

Filing 92

ORDER Granting 91 Stipulation for Extension of Time re 90 Motion for Attorney Fees. Replies due by 10/28/2022. Signed by Judge James C. Mahan on 9/26/2022. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:17-cv-02191-JCM-EJY Document 92 Filed 09/26/22 Page 1 of 3

1
2
3
4
5

JAMES P. KEMP, ESQUIRE
Nevada Bar No. 006375
KEMP & KEMP, ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110,
Las Vegas, NV 89130
[phone] tel./[phone] fax
[e-mail]
Attorney for Plaintiff Thomas Mooney

6

UNITED STATES DISTRICT COURT

7

DISTRICT OF NEVADA

8
9

CASE NO. 2:17-cv-02191-JCM-DJA

THOMAS MOONEY,

10
Plaintiff,

11

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

12
13
14
15
16

STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS’ MOTION
FOR ATTORNEY FEES

v.
FIFE DERMATOLOGY, PC, d/b/a
SURGICAL DERMATOLOGY & LASER
CENTER; DOUGLAS FIFE, M.D.; and
HEATHER FIFE,
.

(First Request)

Defendants.

17
18

The parties, pursuant to LR IA 6-1, by and through their respective counsel, hereby

19

stipulate to extend the time for Plaintiff to respond to Defendants’ MOTION FOR ATTORNEY

20

FEES (ECF No. 90) from the current due date of Monday September 26, 2022 through and

21
22

including Monday, October 10, 2022. The Parties further stipulate that Defendants shall have up
to and including Friday, October 28, 2022 to file their reply in support of Defendants’ MOTION

23
24
25
26
27

FOR ATTORNEY FEES (ECF No. 90).
This is the first request for an extension of this deadline. The parties provide the
following information to the Court regarding the proposed extension of time:
The parties request approval of this stipulation by the court for the following reasons:

28
1

Case 2:17-cv-02191-JCM-EJY Document 92 Filed 09/26/22 Page 2 of 3

1

1. Plaintiff’s counsel, Mr. Kemp, was on vacation out of the country on a long-planned

2

cruise from September 1, 2022 through September 16, 2022 which prevented him from

3

devoting the necessary time to work on this matter until he returned to the office on

4

September 19, 2022;

5
2. Plaintiff’s counsel, Mr. Kemp, also has to travel to Tonopah, Nevada and Denver,

6
7

Colorado for depositions in other matters on September 26 and September 28. He then

8

has a CLE conference at the Nevada Justice Association annual convention in Denver the

9

remainder of next week;

10

3. The Parties have further agreed to extend the time for Defendants’ Reply to Friday,

11

October 28, 2022 to account for time-intensive obligations in other matters, including,

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

12

but not limited to, preparing for and assisting with Day Four of a continued evidentiary

13

hearing set for October 26, 2022 in Case No. 2:20‐cv‐00406‐RFB‐BNW.

14

4. There are no other deadlines or proceedings with which this extension would interfere.

15
16

///

17

///

18

///

19

///

20
21
22

///
///

23

///

24

///

25

///

26

///

27
28
2

Case 2:17-cv-02191-JCM-EJY Document 92 Filed 09/26/22 Page 3 of 3

1

This stipulation to extend the Response and Reply deadlines on Defendants’ Motion

2

for Attorney Fees (ECF No. 90) (to Monday, October 10, 2022 and Friday, October 28,

3

2022, respectively) is brought in good faith and not for purposes of delay.

4
5

DATED this 26th day of September, 2022.

DATED this 26th day of September, 2022.

___/s/ Hayley Cummings
P. SWEN PRIOR, ESQ.
HAYLEY CUMMINGS, ESQ,
SNELL & WILMER
3883 Howard Hughes Pkwy., #1100
Las Vegas, NV 89169
Attorney for Defendants

/s/ James P. Kemp
JAMES P. KEMP, ESQ.
Bar No. 6375
KEMP & KEMP, Attorneys at Law
7435 W. Azure Drive, Suite 110
Las Vegas, NV 89130
Attorney for Plaintiff

6
7
8
9
10
11

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

12
13
14

ORDER

15
16
17
18
19

IT IS SO ORDERED:
____________________________________
UNITED STATES DISTRICT JUDGE
September 26, 2022
DATED: ________________________

20
21
22
23
24
25
26
27
28
3