Cowherd v. My Daily Choice, Inc.

Filing 9

ORDER Granting 7 Stipulation for Extension of Time. My Daily Choice, Inc. answer due 9/1/2024. Signed by Magistrate Judge Nancy J. Koppe on 7/3/2024. (Copies have been distributed pursuant to the NEF - AMMi)

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1 2 3 4 5 6 7 GARMAN TURNER GORDON LLP ERIKA PIKE TURNER Nevada Bar No. 6454 JARED M. SECHRIST Nevada Bar No. 10439 Email: 7251 Amigo Street, Suite 210 Las Vegas, Nevada 89119 Tel: (725) 777-3000 Fax: (725) 777-3112 Attorneys for Defendant My Daily Choice, Inc. UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 11 TRACY COWHERD, individually and on behalf of herself and all others similarly situated, Plaintiff, 12 13 14 v. CASE NO.: 2:24-cv-01128-RFB-NJK STIPULATION AND ORDER TO EXTEND DEFENDANT’S DEADLINE TO FILE RESPONSE TO PLAINTIFF’S COMPLAINT MY DAILY CHOICE, INC, (FIRST REQUEST) Defendant. 15 16 17 Pursuant to LR AI 6-1, Plaintiff, TRACY COWHERD (“Plaintiff”), and Defendant, MY 18 DAILY CHOICE, INC. (“Defendant” together with Plaintiff the “Parties”), through their 19 respective counsel, hereby stipulate and agree as follows: 20 21 22 1. Defendant shall have until September 1, 2024 to file its response to Plaintiff’s Complaint. 2. This request for extension of time is to allow Plaintiff time to seek consolidation of 23 this matter with Case No. 3:24-cv-00254-ART-CSD, currently pending in this District, and, given 24 the complexity of Plaintiff’s allegations, to allow Defendant time to investigate Plaintiff’s claims. 25 3. Defendant expressly reserves all rights, remedies, defenses, objections, and legal 26 arguments, including, but not limited to, its right to move to compel arbitration, its right to move 27 to dismiss any individual or consolidated complaint, its right to challenge joinder of plaintiffs to 28 one another, its right to oppose class certification on any grounds, its rights to oppose consolidation 1 of 2 1 in any other forum or further consolidation in this forum, and its right to file a motion or motions 2 for summary judgment, among others. 3 4 4. This is the Parties’ first request for extension of time this deadline, and it is not intended to cause any delay or prejudice to any party. 5 IT IS SO STIPULATED. 6 Dated this 2nd day of July 2024. Dated this 2nd day of July 2024. 7 GARMAN TURNER GORDON LLP KAZEROUNI LAW GROUP, APC /s/ Jared M. Sechrist ERIKA PIKE TURNER Nevada Bar No. 6454 JARED M. SECHRIST Nevada Bar No. 10439 7251 Amigo Street, Suite 210 Las Vegas, Nevada 89119 /s/ Mona Amini MONA AMINI Nevada Bar No. 15381 GUSTAVO PONCE Nevada Bar No. 15084 6940 S. Cimarron Road, Suite 210 Las Vegas, Nevada 89113 Attorneys for Defendant, My Daily Choice, Inc. 15 SIRI & GLIMSTAD LLP MASON A. BARNEY (pro hac vice forthcoming) TYLER J. BEAN (pro hac vice forthcoming) 745 Fifth Avenue, Suite 500 New York, New York 10151 16 Attorneys for Plaintiff, Tracy Cowherd 8 9 10 11 12 13 14 17 18 ORDER 19 20 IT IS SO ORDERED: 21 22 United States Magistrate Judge 23 DATED: July 3, 2024 24 25 26 27 28 2 of 2

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