Kirk v. Trulite Glass & Aluminum Solutions, LLC et al

Filing 22

ORDER Granting 21 Stipulation to Extend Time Re: 15 Motion to Dismiss. Responses due by 3/28/2018. Replies due by 4/11/2018. Signed by Judge James C. Mahan on 3/23/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:18-cv-00043-JCM-GWF Document 21 Filed 03/21/18 Page 1 of 3

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JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
HKM EMPLOYMENT ATTORNEYS LLP
1785 E. Sahara Ave, Suite 325
Las Vegas, NV 89104
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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LEE KIRK, An Individual
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) CASE NO. 2:18-cv-00043
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Plaintiff,
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vs.
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TRULITE GLASS AND ALUMINUM
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SOLUTIONS, LLC, a Foreign Limited
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Liability Company, HERBERT CORTEZ, )
an Individual, STEVE WILLIAMS,
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an Individual, SHAUN HANNA, an
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Individual, DOES I -X;
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ROE CORPORATIONS I –X.
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Defendants.
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)

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STIPULATION AND ORDER TO EXTEND THE TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS’ MOTION TO DISMISS AND FOR DEFENDANTS
TO FILE THEIR REPLY IN SUPPORT OF THAT MOTION TO DISMISS
(FIRST REQUEST)
COMES NOW, the Plaintiff, LEE KIRK (“Kirk”), by and through his attorney, JENNY

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L. FOLEY, Ph.D., ESQ., of the law firm HKM EMPLOYMENT ATTORNEYS LLP, and

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Defendants, TRULITE GLASS AND ALUMINUM SOLUTIONS, LLC, HERBERT

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CORTEZ, STEVE WILLIAMS, and SHAUN HANNA, (“DEFENDANTS”), by and through

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their attorney, TIMOTHY ROEHRS, ESQ., of LITTLER MENDELSON, P.C. and hereby

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stipulate and agree as follows:

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Page 1 of 4

Case 2:18-cv-00043-JCM-GWF Document 21 Filed 03/21/18 Page 2 of 3

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1.

That the Opposition to the Defendants’ Motion to Dismiss that was due on

March 20th, 2018, will now be due on March 28th, 2018.
2.

That the Reply to the Opposition to the Defendants’ Motion to Dismiss will then

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be due on April 11, 2018.
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3.

This request for an extension of time is made in good faith and not for purpose

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of delay and is based on Plaintiff’s council experiencing the death of two immediate family

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members and Defendants requiring additional time to file their Reply brief in light of Plaintiff’s

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Opposition being filed at a later date.

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4.

This is the first request for an extension of time with respect to the Opposition

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and Reply briefs associated with Defendants’ Motion to Dismiss.

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Dated this __21st_ day of March, 2018.

Dated this __21st___ day of March, 2018.

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HKM Employment Attorneys LLP

Littler Mendelson P.C.

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/s/ Jenny L. Foley

_/s/ Timothy Roehrs
Timothy Roehrs, Esq.
Nevada Bar No. 9668
3960 Howard Hughes Parkway,
Suite 300
Las Vegas, Nevada 89169

Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave., Suite 325
Las Vegas, Nevada 89104

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ORDER

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Case 2:18-cv-00043-JCM-GWF Document 21 Filed 03/21/18 Page 3 of 3

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The Court having reviewed the foregoing STIPULATION TO EXTEND THE TIME

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FOR PLAINTIFF TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS AND FOR

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DEFENDANTS TO FILE THEIR REPLY IN SUPPORT OF THAT MOTION TO DISMISS

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in the above-entitled matter and for good cause appearing therefor,
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IT IS SO ORDERED that the Opposition to the Defendants’ Motion to Dismiss shall
be due on March 28th, 2018;
IT IS SO ORDERED that the Reply to the Opposition to the Defendants’ Motion to
Dismiss shall be due on April 11, 2018.

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Dated:

March 23, 2018

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UNITED STATES MAGISTRATE JUDGE
STATES DISTRICT JUDGE

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Respectfully submitted by:
HKM Employment Attorneys LLP

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/s/ Jenny L. Foley
Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave, Suite 325
Las Vegas, Nevada 89104
Attorney for Plaintiff

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