Reno v. Western Cab Company et al

Filing 208

ORDER Granting 207 Stipulation for Extension of Time re 196 Motion to Compel (Second Request). See Order for deadlines. Signed by Magistrate Judge Nancy J. Koppe on 8/12/2020. (Copies have been distributed pursuant to the NEF - MR)

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MARIO P. LOVATO
Nevada Bar No. 7427
LOVATO LAW FIRM, P.C.
7465 W. Lake Mead Blvd. Ste. 100
Las Vegas, Nevada 89128
T: [phone]
[e-mail]
Attorney for Defendants
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
MICHAEL RENO, ERIC KIEFABER,
DENNIS RHOADES, JASON HARRIS,
PREMIER TAMAYO, WILFREDO
ALLANIGUE, and ARIES BIHASA,

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Plaintiffs,
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vs.
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WESTERN CAB COMPANY, HELEN
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TOBMAN MARTIN, MARILYN
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TOBMAN MORAN, JANIE TOBMAN
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MOORE, MARTHA SARVER, and
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JASON AWAD,
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Defendants.
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___________________________________ )

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CASE NO. 2:18-CV-840-APG-NJK

STIPULATION
IT IS HEREBY STIPULATED AND AGREED by and between counsel for the parties

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that the deadline for Defendants to file their response to Plaintiffs’ Motion to Compel FCRP Rule
30(b)(6) deposition (#196) be EXTENDED such that Defendants’ response filed on August 11,
2020 shall be deemed timely nunc pro tunc so that the arguments may be heard on the merits.

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IT IS FURTHER STIPULATED AND AGREED by and between counsel for the parties

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that that the deadline for Plaintiffs to file their reply to such response shall be EXTENDED such

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that Plaintiffs’ Reply shall be due on August 18, 2020 and not August 14, 2020 as provided by the
Court's Order (Docket 205) so as to afford Plaintiffs' the seven (7) days contemplated by that Order

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to prepare and file such reply.
In support of this Stipulation, the parties submit that such extensions are minor, that they
are entered into in light of the intervening weekend that otherwise reduces the time for submitting

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the respective response and reply, that defense counsel was out-of-the-office for a pre-planned
matter from July 30, 2020 to August 4, 2020, that both defense counsel and Plaintiffs’ counsel

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submitted timely filings seeking limited extensions in light of the above, and that this provides for

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prompt submission of briefing addressing the merits of the motion while also allowing counsel to

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handle obligations coming due in this, and other, matters.

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Dated: August 12, 2020.

Dated: August 12, 2020.

LEON GREENBERG
PROFESSIONAL CORPORATION

LOVATO LAW FIRM, P.C.

/s/ Leon Greenberg
LEON GREENBERG, ESQ.
Nevada Bar No. 8094
2965 South Jones Blvd., #E3
Las Vegas, NV 89146
Tel [phone]
Fax [phone]
Attorneys for Plaintiffs

/s/ Mario Lovato
MARIO P. LOVATO
Nevada Bar No. 7427
Attorney for Defendants

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ORDER

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IT IS SO ORDERED.

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DATED: August _____, 2020.

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UNITED STATES MAGISTRATE JUDGE

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