Carr v. United States of America et al

Filing 29

ORDER Granting 28 Stipulation for Extension of Time re 26 Motion to Dismiss (First Request). Responses due by 8/2/2021. Replies due by 8/23/2021. Signed by Judge Gloria M. Navarro on 7/14/2021. (Copies have been distributed pursuant to the NEF - MR)

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MELANIE A. HILL, ESQ.
Nevada Bar No. 8796
MELANIE HILL LAW PLLC
1925 Village Center Circle, Suite150
Las Vegas, NV 89134
Tel.: [phone]
Fax.: [phone]
Email: [e-mail]
Attorneys for Plaintiff Steven Earl Carr

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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STEVEN EARL CARR, an individual,

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Plaintiff,

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Case No.: 2:20-cv-01850-GMN-NJK
v.
UNITED STATES OF AMERICA; DAVID
N. KARPEL, individually, DOES 1 through
100; and ROES 1 through 100; inclusive,

STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR PLAINTIFF
TO RESPOND TO MOTION TO DISMISS
FILED BY DEFENDANTS UNITED STATES
OF AMERICA AND DAVID N. KARPEL
[ECF No. 26] AND FOR DEFENDANTS TO
FILE THEIR REPLY

Defendants.
(First Request)

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NOW COMES the Plaintiff, STEVEN EARL CARR, by and through his attorneys, Melanie

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A. Hill and Melanie Hill Law PLLC, and Defendants UNITED STATES OF AMERICA and DAVID

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N. KARPEL, by and through their attorneys, Assistant United States Attorney Gregory Addington,

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who hereby stipulate that Plaintiffs may have an extension of time from the current deadline of July

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16, 2021 until August 2, 2021, within which to respond to the Defendants’ Motions to Dismiss [ECF

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No. 26]. The parties further stipulate that Defendants shall have an extension of time from the current

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deadline of July 23, 2021 until August 23, 2021 to file their reply in support of the Motion to Dismiss

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[ECF No. 26]. This Stipulation is made at the request of all parties for the reasons set forth herein

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

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and this is the first request for an extension of the deadlines to respond and reply to the pending

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Motion to Dismiss [ECF No. 26].

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In support of this Stipulation and Order, the parties state as follows:

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1. The second amended complaint was filed in this case on July 2, 2021 [ECF No. 25] after

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the Court entered an Order granting Plaintiff’s Motion for Leave to File Proposed Second Amended
Complaint and denying Defendants’ Motion to Dismiss as moot on July 2, 2021 [ECF No. 24].

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2. Defendants filed their Motion to Dismiss Plaintiff’s Second Amended Complaint on July

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2, 2021 [ECF No. 26].

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3. Counsel for all parties have conferred regarding Plaintiffs’ request for an extension of the

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response deadline given her vacation from July 2, 2021 until July 14, 2021, and counsel for the

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Defendants has agreed to the requested extension. Defendants have also requested an extension of

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their reply deadline due to their early August vacation and Plaintiff has agreed.

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4. This stipulation and order are being brought in good faith and is not sought for any

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improper purpose or other purpose of delay, but to allow counsel for the parties’ additional time to

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respond and reply to the motion to dismiss and brief the necessary issues raised in the motion to

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dismiss due to their summer vacation schedules and unavailability.

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

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WHEREFORE, the parties respectfully request that the Court extend the deadline for Plaintiff

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to respond to Defendants’ Motion to Dismiss [ECF No. 26] from the current deadline of July 16,

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2021 until August 2, 2021. The parties further respectfully request that the Court extend the deadline
for Defendants to file their reply from the current deadline of July 23, 2021 until August 23, 2021.

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DATED this 13th day of July, 2021.
Respectfully submitted,

Respectfully submitted,

MELANIE HILL LAW PLLC

CHRISTOPHER CHIOU
Acting United States Attorney

/s/ Melanie A. Hill
__________________________________
Melanie A. Hill, Esq. (NV Bar No. 8796)
1925 Village Center Circle, Suite 150
Las Vegas, NV 891034
Tel.: [phone]
Email: [e-mail]
Attorney for Plaintiff Steven Earl Carr

/s/ Gregory Addington
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Gregory Addington (NV Bar No. 6875)
Assistant United States Attorney
400 South Virginia Street, Suite 900
Reno, NV 89501
Tel.: [phone]
Email: [e-mail]
Attorney for Defendants United States of
America, David L. Jaffe, and David N. Karpel

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IT IS SO ORDERED.

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Dated this ____ day of July, 2021.

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IT IS SO ORDERED:

______________________________________
UNITED STATES DISTRICT JUDGE
___________________________
Gloria M. Navarro, District Judge
UNITED STATES DISTRICT COURT

DATED: _________________

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

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