Borenstein v. Lead Animal Shelter Animal Foundation et al
Filing
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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)
Case 2:19-cv-00985-APG-DJA Document 196 Filed 09/08/21 Page 1 of 2
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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
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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BRIAN BORENSTEIN,
Case No.: 2:19-cv-00985-APG-DJA
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300 South 4th Street, Suite 830
Las Vegas, Nevada 89101
(702) 776-7000 FAX: (702) 776-7900
REID RUBINSTEIN & BOGATZ
Plaintiff,
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v.
THE ANIMAL FOUNDATION, et al.,
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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]
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[FIRST REQUEST]
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IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff, BRIAN
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BORENSTEIN, and Defendant, CARLY SCHOLTEN, by and through their undersigned counsel,
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that Defendants The Animal Foundation (“TAF”) and Ms. Carly Scholten (collectively with TAF
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the “TAF Defendants”) may have additional time within which to respond to Plaintiff’s Second
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Amended Complaint [ECF No. 189].
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Plaintiff’s Second Amended Complaint was filed on August 23, 2021. Defense counsel has
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requested an additional week to prepare a response, to which counsel for Plaintiff’s has graciously
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agreed. Therefore, the parties hereby stipulate that the last day for TAF Defendants to respond to
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Plaintiff’s Second Amended Complaint is extended from Tuesday, September 7, 2021 to Tuesday,
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September 14, 2021.
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Further, in light of travel plans and other obligations of Plaintiff’s counsel, the Parties
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stipulate and request that Plaintiff’s deadline to file a reply thereto be extended for a week from
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Tuesday, September 28, 2021 to Tuesday, October 5, 2021.
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Case 2:19-cv-00985-APG-DJA Document 196 Filed 09/08/21 Page 2 of 2
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This request is made in good faith and not for the purpose of undue delay. This document
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is being electronically filed through the Court’s CM/ECF System. Accordingly, counsel for
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Defendants hereby attests that (1) the content of this document is acceptable to all persons required
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to sign the document; (2) Plaintiff’s counsel has concurred with the filing of this document and
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has authorized defense counsel to affix his electronic signature hereto; and (3) a record supporting
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this concurrence could be made available if so ordered by this Court.
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Dated this 7th day of September, 2021.
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Respectfully submitted,
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300 South 4th Street, Suite 830
Las Vegas, Nevada 89101
(702) 776-7000 FAX: (702) 776-7900
REID RUBINSTEIN & BOGATZ
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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
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Robert S. Melcic, Esq. (14923)
4930 Mar Vista Way
Las Vegas, NV 89121
Attorneys for Plaintiff
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ORDER
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IT IS SO ORDERED.
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DATED this 8th day of September 2021.
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DATED this ___________ day of _________________, 2021.
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___________________________________
Daniel J. Albregts
United States Magistrate Judge
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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
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