Bryant v Madison Management Services, LLC, et al

Filing 34

ORDER granting 31 Motion to Extend Time to Answer 30 Amended Complaint. Madison Management Services, LLC answer due 12/17/2020; Waldman and Porras, PLLC answer due 12/17/2020. Signed by Magistrate Judge Elayna J. Youchah on 12/3/2020. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00594-JAD-EJY Document 34 Filed 12/03/20 Page 1 of 5

Nicholas M. Porras
(NV Bar No. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246
FAX: [phone]
Attorneys for Defendants,
Madison Management Services, PLLC
Waldman & Porras, PLLC
IN UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
LAS VEGAS DIVISION
LISA A. BRYANT,

Civil Action No. 2:20-cv-00594-JAD-EJY

Plaintiff,
vs.

DEFENDANTS’ NOTICE OF CORRECTED
FILING REGARDING DEFENDANTS’
MOTION FOR EXTENSION OF TIME FOR
DEFENDANTS MADISON MANAGEMENT
SERVICES , LLC AND WALDMAN &
PORRAS, PLLC’S TO FILE AN ANSWER
TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

MADISON MANAGEMENT SERVICES,
LLC AND WALDMAN & PORRAS,
PLLC,
Defendant.

TO THE HONORABLE JUDGE OF SAID COURT:
DEFENDANTS MADISON MANAGEMENT SERVICES , LLC AND WALDMAN &
PORRAS, PLLC. (“Defendants”), hereby respectfully notifies this Court that in filing yesterday
afternoon their Motion for Extension of Time to Respond to Plaintiff’s First Amended
Complaint, Defendants’ inadvertently uploaded an unrevised version of the motion. The motion
had conflicts in the “conferred” section of the first paragraph, we were unable to make contact.
It also had a conflict of the time requested to respond requesting 14 days in the first paragraph

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Case 2:20-cv-00594-JAD-EJY Document 34 Filed 12/03/20 Page 2 of 5

and 15 days in the closing and the inadvertent omission of a signature by the undersigned. The
corrected motion is attached to this Notice of Corrected Filing.
Defendants therefore respectfully ask this Court to accept the Notice of Corrected filing and the
attached Motion.
Dated: December 3, 2020
Respectfully Submitted,

By:__Nicholas M. Porras__
Nicholas M. Porras
(NV Bar NO. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246

CERTIFICATE OF SERVICE
Pursuant to Rule 5 of the Federal Rules of Civil Procedure, the undersigned counsel for
the Defendant certifies that the foregoing document has been filed with the Court and served
upon all known counsel of record via the Court’s electronic case filing system and by first class
mail, on December 3, 2020.
/s/ Nicholas M. Porras
Nicholas M. Porras
(NV Bar NO. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246
FAX:[phone]

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Case 2:20-cv-00594-JAD-EJY Document 34 Filed 12/03/20 Page 3 of 5

Nicholas M. Porras
(NV Bar No. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246
FAX: [phone]
Attorneys for Defendants,
Madison Management Services, PLLC
Waldman & Porras, PLLC

IN UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
LAS VEGAS DIVISION
LISA A. BRYANT,

Civil Action No. 2:20-cv-00594-JAD-EJY

Plaintiff,
vs.

MOTION FOR EXTENSION OF TIME FOR
DEFENDANTS MADISON MANAGEMENT
SERVICES , LLC AND WALDMAN &
PORRAS, PLLC’S TO FILE AN ANSWER
TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

MADISON MANAGEMENT SERVICES,
LLC AND WALDMAN & PORRAS,
PLLC,
Defendant.

TO THE HONORABLE JUDGE OF SAID COURT:
DEFENDANTS MADISON MANAGEMENT SERVICES , LLC AND WALDMAN &
PORRAS, PLLC. (“Defendants”), hereby respectfully request an extension of time of fifteen
(15) days for Defendant to respond to Plaintiff’s First Amended Complaint.

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Defendants

Case 2:20-cv-00594-JAD-EJY Document 34 Filed 12/03/20 Page 4 of 5

attempted to confer with Plaintiff but were unable to make contact. In further support of this
motion, Defendants state as follows:
1.

On November 11, 2020, Plaintiff filed her First Amended Complaint in

the above referenced case.
2.

Defendant Madison Management Services, LLC Defendant Waldman &

Porras, PLLC Answer is currently due on December 2, 2020.
3.

The undersigned was diagnosed positive with Covid-19 on November 11,

2020 and was ill and in quarantine out of state.
4.

The undersigned is currently struggling with a backlog of work while still

experiencing remaining symptoms.
5.

On December 2, 2020, Christopher M. Jordan, Of Counsel for Defendant,

attempted to confer telephonically with George Haines, Lead Counsel for Plaintiff, about
extending Defendants’ answers deadline and emailed the team as well.
6. The Defendants are requesting that Answers to the First Amended Complaint should be
extended by fourteen (15) days, which would make new answer deadline December 17,
2020.
7.

The relief requested herein is not for delay but so that justice may be done.

Further, this relief will not result in any undue delay in the administration of this case.
WHEREFORE, PREMISES CONSIDERED, Defendant, with Plaintiff’s agreement,
respectfully requests this Court extend the time for Defendant to respond to Plaintiff’s First
Amended Complaint to December 17, 2020.

Dated: December 2, 2020
Respectfully submitted,

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Case 2:20-cv-00594-JAD-EJY Document 34 Filed 12/03/20 Page 5 of 5

/s/ Nicholas M. Porras
Nicholas M. Porras
(NV Bar NO. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246
FAX:[phone]

CERTIFICATE OF CONFERENCE
I hereby certify that I attempted to confer with Counsel for Plaintiff by phone and email
on December 2, 2020, about whether Plaintiff agrees to the request that Defendants seek in this
motion. I was unable to make contact.
/s/ Nicholas M. Porras
Nicholas M. Porras

CERTIFICATE OF SERVICE
Pursuant to Rule 5 of the Federal Rules of Civil Procedure, the undersigned counsel for
the Defendant certifies that the foregoing document has been filed with the Court and served
upon all known counsel of record via the Court’s electronic case filing system and by first class
mail, on December 2, 2020.
/s/ Nicholas M. Porras
Nicholas M. Porras
(NV Bar NO. 12849)
[e-mail]
Waldman & Porras, PLLC
201 West Liberty St. Ste. 207
Reno, NV 89501
PH: 775.525.9246
FAX:[phone]

IT IS SO ORDERED.

____________________________
U.S. MAGISTRATE JUDGE
Dated: December 3, 2020

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