Palmeri v. United Rentals (North America), Inc.

Filing 11

ORDER Granting #10 Stipulation for Extension of Time (Third Request). United Rentals (North America), Inc. Answer re #1 Petition for Removal due 2/3/2023. Signed by Magistrate Judge Nancy J. Koppe on 1/17/2023. (Copies have been distributed pursuant to the NEF - TRW)

Case 2:22-cv-01981-JCM-NJK Document 11 Filed 01/17/23 Page 1 of 2

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JOSHUA A. SLIKER, ESQ
Nevada Bar No. 12493
JACKSON LEWIS P.C.
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
Telephone: [phone]
Email: [e-mail]
Attorneys for Defendant
United Rentals (North America), Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JAMES PALMERI,

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Plaintiff,
vs.
UNITED RENTALS (NORTH AMERICA),
INC.; DOE INDIVIDUALS I through X; and
ROE ENTITIES I through X,
Defendants.

Case No.: 2:22-cv-1981-JCM-NJK
ORDER
EXTENDING TIME FOR DEFENDANT
UNITED RENTALS (NORTH
AMERICA), INC. TO RESPOND TO
PLAINTIFF’S COMPLAINT (ECF NO.
1-1)
(THIRD REQUEST)

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Defendant United Rentals (North America), Inc. (“Defendant” or “United Rentals”), by and

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through its counsel, the law firm of Jackson Lewis P.C., and Plaintiff James Palmeri, by and through

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his counsel, Glenn Schepps, Esq., hereby stipulate and agree to extend the time for Defendant to

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file its response to Plaintiff’s Complaint (ECF No. 1-1) up to and including February 3, 2022.

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This is the third request for an extension of time for Defendant to respond to Plaintiff’s

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Complaint. Defendant filed a motion seeking an extension on December 5, 2022. ECF No. 4. The

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Court granted Defendant’s motion on December 14, 2022. ECF No. 6. Defendant’s response to

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Plaintiff’s Complaint is currently due on December 16, 2022. Id. On December 15, 2022, the parties

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stipulated to extend Defendant’s time to answer to January 13, 2023 in order to allow time for the

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parties to engage in settlement discussions.

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The parties have agreed to again extend the deadline for Defendant to file its response to

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the Complaint because they remain engaged in settlement discussions. Currently, the parties are

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finalizing the terms of a stipulated protective order which they anticipate submitting to the Court

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next week to facilitate the exchange of sensitive documents which will aid the parties’ settlement

Case 2:22-cv-01981-JCM-NJK Document 11 Filed 01/17/23 Page 2 of 2

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discussions. The parties have made significant progress in their discussions and anticipate a

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resolution one way or another soon. The length of the extension takes into account the fact that

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Defendant’s counsel will be out of the office and travelling from January 19th to January 29, 2023.

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The parties believe these circumstances constitute good cause for granting an extension because

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doing so will allow time to attempt to settle this case at the outset, and thus, if successful, avoid the

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need for the parties and the Court to expend time and resources on motion practice related to

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Plaintiff’s arbitration agreement and substance of the Complaint. See Fed. R. Civ. P. 6(b)(1); Wong

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v. Regents of the Univ. of Calif., 410 F.3d 1052, 1060 (9th Cir. 2005).

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Dated this 13th day of January, 2023.

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LEGAL RESOURCE GROUP

JACKSON LEWIS P.C.

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/s/ Glenn Schepps___________________
GLENN SCHEPPS, ESQ.
Nevada Bar No. 4742
205 N. Stephanie Street, Suite D221
Henderson, Nevada 89074

/s/ Joshua A. Sliker
JOSHUA A. SLIKER, ESQ
Nevada Bar No. 12493
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101

Attorneys for Plaintiff James Palmeri

Attorneys for Defendant
United Rentals (North America), Inc.

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ORDER
IT IS SO ORDERED.

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__________________________

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UNITED STATES MAGISTRATE JUDGE

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January 17, 2023
Date: ______________________

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