Jackson v. Spring Valley Health Care, LLC

Filing 7

ORDER Granting 5 First Stipulation for Extension of Time Re: 1 Complaint. Spring Valley Health Care, LLC's answer due 7/20/2018. Signed by Magistrate Judge Carl W. Hoffman on 7/11/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:18-cv-01064-JAD-CWH Document 5 Filed 07/05/18 Page 1 of 2

1 BRUCE C. YOUNG, ESQ., NV Bar # 5560
SCOTT H. BARBAG, ESQ., NV Bar # 14164
2 LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
3 Las Vegas, Nevada 89118
TEL: [phone]
4 FAX: [phone]
[e-mail]
5 [e-mail]
Attorneys for Defendant Spring Valley Health
6 Care, LLC, d/b/a Spanish Hills Wellness Suites
7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11 KAYATANA JACKSON, individually,
Plaintiff,

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13

CASE NO. 2:18:-cv-01064-JAD-CWH

vs.

14 SPRING VALLEY HEALTH CARE, LLC,
d/b/a SPANISH HILLS WELLNESS SUITES,
15 a foreign limited-liability company; DOES IX; and ROE BUSINESS ENTITIES I-X,
16 inclusive

STIPULATION AND ORDER
EXTENDING TIME FOR DEFENDANT
SPRING VALLEY HEALTH CARE, LLC
TO FILE AN ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S
COMPLAINT
(FIRST REQUEST)

Defendants.

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Plaintiff Kayatana Jackson (“Plaintiff”) and Defendant Spring Valley Health Care, LLC

20 d/b/a Spanish Hills Wellness Suites (“Defendant”), by and through their respective counsel,
21 hereby stipulate to extend the time for Defendant to file an Answer or otherwise respond to the
22 Complaint in this matter.
23

Plaintiff’s Complaint (ECF No. 1) was filed with this Court on June 13, 2018. Defendant’s

24 registered agent was served with a copy of the Summons and Complaint on June 15, 2018. Thus,
25 the current deadline for Defendant to Answer or otherwise respond to the Complaint is July 6,
26 2018. Counsel for Defendant needs additional time to investigate potential conflicts and/or obtain
27 conflict waivers from Defendant and from firm clients in an unrelated matter in order to ethically

LEWIS

28 represent Defendant and those parties in separate lawsuits.

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4822-1957-4892.1

Case 2:18-cv-01064-JAD-CWH Document 5 Filed 07/05/18 Page 2 of 2

1

In order to provide counsel for Defendant sufficient time to appropriately address this

2 potential conflict issue, counsel for Plaintiff and Defendant have agreed to extend the deadline for
3 Defendant to Answer or otherwise respond to Plaintiff’s Complaint (ECF No. 1) up to and
4 including July 20, 2018. This is the first request by the parties for an extension of time for
5 Defendant to Answer or otherwise respond to Plaintiff’s Complaint (ECF No. 1). The parties
6 represent that the time to Answer has not yet expired and this request for extension is not for an
7 improper purpose or to unnecessarily delay this litigation.
8

WHEREFORE, Plaintiff and Defendant respectfully request that this Court enter an Order

9 granting this Stipulation Extending Time for Defendant Spring Valley Health Care, LLC to File an
10 Answer or Otherwise Respond to Plaintiff’s Complaint and extending the deadline for Defendant
11 to file its responsive pleading to Plaintiff’s Complaint up to and including July 20, 2018.
12 DATED this 5th day of July, 2018.
13
14 MAIER GUTIERREZ & ASSOCIATES

LEWIS BRISBOIS BISGAARD &
SMITH LLP

15
16 /s/ Danielle J. Barraza
Joseph A. Gutierrez, Esq.
17 Danielle J. Barraza, Esq.

/s/ Bruce C. Young
Bruce C. Young, Esq.
Scott H. Barbag, Esq.

18 Attorneys for Plaintiff Kayatana Jackson

Attorneys for Defendant Spring Valley
Health Care, LLC, d/b/a Spanish Hills
Wellness Suites

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20
21

IT IS SO ORDERED:

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24

_________________________________________
UNITED STATES DISTRICT COURT JUDGE
MAGISTRATE

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July 11, 2018
DATED: _________________________________

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27

LEWIS

28

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4822-1957-4892.1

2