Borenstein v. Lead Animal Shelter Animal Foundation et al

Filing 196

ORDER Granting 194 Stipulation for Extension of Time re 189 Second Amended Complaint (First Request). Carly Scholten, The Animal Foundation answer due 9/14/2021. Signed by Magistrate Judge Daniel J. Albregts on 9/8/2021. (Copies have been distributed pursuant to the NEF - MR)

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Case 2:19-cv-00985-APG-DJA Document 196 Filed 09/08/21 Page 1 of 2 1 2 3 4 5 6 REID RUBINSTEIN & BOGATZ I. SCOTT BOGATZ, ESQ. Nevada Bar No. 3367 KERRY E. KLEIMAN, ESQ. Nevada Bar No. 14071 300 South 4th Street, Suite 830 Las Vegas, Nevada 89101 Telephone: (702) 776-7000 Facsimile: (702) 776-7900 sbogatz@rrblf.com kkleiman@rrblf.com Attorneys for Defendant 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 BRIAN BORENSTEIN, Case No.: 2:19-cv-00985-APG-DJA 10 12 300 South 4th Street, Suite 830 Las Vegas, Nevada 89101 (702) 776-7000 FAX: (702) 776-7900 REID RUBINSTEIN & BOGATZ Plaintiff, 11 v. THE ANIMAL FOUNDATION, et al., 13 Defendants. STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANTS THE ANIMAL FOUNDATION & CARLY SCHOLTEN TO REPLY TO PLAINTIFF’S SECOND AMENDED COMPLAINT [ECF NO. 189] 14 [FIRST REQUEST] 15 16 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff, BRIAN 17 BORENSTEIN, and Defendant, CARLY SCHOLTEN, by and through their undersigned counsel, 18 that Defendants The Animal Foundation (“TAF”) and Ms. Carly Scholten (collectively with TAF 19 the “TAF Defendants”) may have additional time within which to respond to Plaintiff’s Second 20 Amended Complaint [ECF No. 189]. 21 Plaintiff’s Second Amended Complaint was filed on August 23, 2021. Defense counsel has 22 requested an additional week to prepare a response, to which counsel for Plaintiff’s has graciously 23 agreed. Therefore, the parties hereby stipulate that the last day for TAF Defendants to respond to 24 Plaintiff’s Second Amended Complaint is extended from Tuesday, September 7, 2021 to Tuesday, 25 September 14, 2021. 26 Further, in light of travel plans and other obligations of Plaintiff’s counsel, the Parties 27 stipulate and request that Plaintiff’s deadline to file a reply thereto be extended for a week from 28 Tuesday, September 28, 2021 to Tuesday, October 5, 2021. Page 1 of 2 Case 2:19-cv-00985-APG-DJA Document 196 Filed 09/08/21 Page 2 of 2 1 This request is made in good faith and not for the purpose of undue delay. This document 2 is being electronically filed through the Court’s CM/ECF System. Accordingly, counsel for 3 Defendants hereby attests that (1) the content of this document is acceptable to all persons required 4 to sign the document; (2) Plaintiff’s counsel has concurred with the filing of this document and 5 has authorized defense counsel to affix his electronic signature hereto; and (3) a record supporting 6 this concurrence could be made available if so ordered by this Court. 7 8 Dated this 7th day of September, 2021. 9 Respectfully submitted, 11 12 300 South 4th Street, Suite 830 Las Vegas, Nevada 89101 (702) 776-7000 FAX: (702) 776-7900 REID RUBINSTEIN & BOGATZ 10 REID RUBINSTEIN & BOGATZ THE PALMER LAW FIRM, P.C. By: /s/ Kerry E. Kleiman I. Scott Bogatz, Esq. (3367) Kerry E. Kleiman, Esq. (14071) REID RUBINSTEIN & BOGATZ 300 South Fourth Street, Suite 830 Las Vegas, Nevada 89101 Attorneys for Defendants The Animal Foundation & Carly Scholten, COO By: /s/ Raelene K. Palmer Raelene K. Palmer, Esq. (8602) 5550 Painted Mirage Road, Suite 320 Las Vegas, Nevada 89149 13 14 15 16 17 Robert S. Melcic, Esq. (14923) 4930 Mar Vista Way Las Vegas, NV 89121 Attorneys for Plaintiff 18 19 20 ORDER 21 22 IT IS SO ORDERED. 23 DATED this 8th day of September 2021. 24 DATED this ___________ day of _________________, 2021. 25 26 27 ___________________________________ Daniel J. Albregts United States Magistrate Judge ____________________________________ UNITED STATES DISTRICT JUDGE UNITED STATES MAGISTRATE JUDGE 28 Page 2 of 2

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