Thornton v. Portola Del Sol Operator, LLC et al

Filing 86

ORDER granting 83 Stipulation to Extend Deadline to File Response to 81 Motion to Dismiss Responses due by 2/16/2024. Signed by Judge Andrew P. Gordon on 2/2/2024. (Copies have been distributed pursuant to the NEF - CT)

1
2
3
4
5
6

ELIZABETH S. CARMONA, ESQ.
Nevada State Bar No. 14687
KRISTOPHER S. PRE, ESQ.
Nevada State Bar No. 14106
NEVADA LEGAL SERVICES, INC.
701 E. Bridger Ave. Suite 400
Las Vegas, Nevada 89101 Telephone:
[phone], ext. 128
[e-mail]
[e-mail]
Attorneys for Peggy Thornton
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

7
8
9

UNITED STATES OF AMERICA
ex rel. PEGGY THORNTON, Relator,

No.: 2:21-CV-01123-APG-BNW

11

PEGGY THORNTON,

12

Plaintiff,

STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
RESPONSIVE PLEADINGS TO
MOTION TO DISMISS AMENDED
COMPLAINT BY DEFENDANT TMIF II
PORTOLA, LLC.

13

v.

FIRST REQUEST

10

14
15
16
17
18
19

and

PORTOLA DEL SOL OPERATOR, LLC, a
foreign limited-liability company; TMIF II
PORTOLA, LLC, a foreign limited-liability
company; APARTMENT MANAGEMENT
CONSULTANTS, LLC, a foreign limited
liability company, and RENE
RICHARDSON, as AGENT of PORTOLA
DEL SOL OPERATOR, LLC.
Defendants.

20
21
22

Plaintiff Peggy Thornton (“Thornton”) (collectively “Plaintiff”), Defendant TMIF II
Portola, LLC (“TMIF”), by and through their undersigned attorneys, and pursuant to LR IA 6-1,
submit the following Stipulation and Order to Extend Deadline to File Responsive Pleadings to

23
24
1

1

Motion to Dismiss Amended Complaint by Defendant TMIF II Portola, LLC. up to and including

2

February 16, 2024. In support of the Stipulation, the parties state the following:

3

1.

4
5

Thornton’s responsive pleading to TMIF’s Motion to Dismiss is currently due February 2,

2024.
2.

Because counsel for Thornton has pre-existing scheduling conflicts and recent staffing

changes, Plaintiff requested a two-week extension until February 16, 2024.

6

3.

7

extension will not impact any other deadlines in this case.

8

4.

9
10

Counsel for TMIF II Portola, LLC. has agreed to the requested extension and the requested
This is the first request to extend the deadline for Thornton to file their responsive pleading

to TMIF’s Motion to Dismiss.
5.

This request for an extension of time is not intended to cause any undue delay or prejudice

to any party.

11

6.

12

pleadings shall be extended through February 16, 2024.

13

Dated this 1st day of February, 2024.

14

Therefore, the Parties hereby stipulate that the deadline for Thornton to file their responsive

NEVADA LEGAL SERVICES, INC.

McDONALD CARANO LLP

By: /s/ Kristopher S. Pre
Peter C. Wetherall (NSBN 4414)
Elizabeth S. Carmona (NSBN 14687)
Kristopher Pre (NSBN 14106)
701 E. Bridger Avenue, Suite 400
Las Vegas, Nevada 89101

By: /s/ John A. Fortin
Rory T. Kay (NSBN 12416)
John A. Fortin (NSBN 15221)
Karyna M. Armstrong (NSBN 16044)
2300 West Sahara Avenue, Suite 1200
Las Vegas, Nevada 89102

15
16
17
18
19

Attorneys for Plaintiffs

Attorneys for Defendant TMIF II Portola, LLC

20
IT IS SO ORDERED:

21
22
23

________________________________
UNITED STATES DISTRICT JUDGE

24

February 2, 2024
DATED: ___________________

2