Doe v. Juan

Filing 27

ORDER Granting #26 Stipulation to Extend Time to Respond to Plaintiff Jacqueline Nichols's #22 First Amended Complaint. Jack Juan answer due 3/18/2025. Signed by Magistrate Judge Nancy J. Koppe on 3/11/2025. (Copies have been distributed pursuant to the NEF - JG)

1 LEWIS BRISBOIS BISGAARD & SMITH LLP
ELLEN JEAN WINOGRAD
2 Nevada Bar No. 815
[e-mail]
3 PHILIP J. TACASON
Nevada Bar No. 15655
4 [e-mail]
5555 Kietzke Lane, Suite 200
5 Reno, Nevada 89511
Telephone: [phone]
6 Facsimile: 775.827.9256
7 Attorneys for Defendant JACK JUAN
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JACQUELINE NICHOLS, individually,

Case No. 2:25-cv-00120-GMN-NJK

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Plaintiff,
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vs.

13 JACK JUAN, an individual; DOES I through
X; ROE Corporations I through X, inclusive,
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Defendants.
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LEWIS

STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO RESPOND TO
PLAINTIFF JACQUELINE NICHOLS’S
FIRST AMENDED COMPLAINT (FIRST
REQUEST)

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Plaintiff JACQUELINE NICHOLS, by and through her attorneys of record, Margaret A.

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McLetchie and Leo S. Wolpert of McLETCHIE LAW, and Defendant JACK JUAN, by and

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through his attorneys of record, Ellen J. Winograd and Philip J. Tacason of LEWIS BRISBOIS

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BISGAARD & SMITH LLP (collectively “the Parties”), submit the following STIPULATION

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AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO PLAINTIFF

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JACQUELINE NICHOLS’S FIRST AMENDED COMPLAINT (FIRST REQUEST). The

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Parties stipulate to extend the time within which Defendant may respond to Plaintiff’s First

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Amended Complaint by 21 days.

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The parties seek this extension of time because Defendant’s lead counsel had a series of

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medical incidents, beginning February 19, 2025. Counsel was travelling out-of-state. See LR IA

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6-1(a) (providing that a request to extend time “must state the reasons for the extension

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requested.”). Should the Court require further information on Defendant’s counsel’s medical

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condition, counsel will submit additional information and documentation to the Court in camera.

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

153899935.1

1

Plaintiff requires further time to respond to any motion to dismiss because lead counsel

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for Plaintiff has an evidentiary hearing March 24-March 28, 2025, and will be preparing for the

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same March 17-March 23, 2-25. Further, lead counsel for Plaintiff has oral argument at the

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Nevada Supreme Court April 8, 2025.

5

A.

Proposed deadline to respond to First Amended Complaint.

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7
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Current
Event
Deadline to Respond to
First Amended Complaint March 11, 2025

March 18, 2025

Deadline to Reply to
Motion to Dismiss
Amended Complaint

If the Court grants the extension as to
Defendant Juan’s deadline, LR 7-2 provides 14
days within which to respond to a
motion. Thus, if Defendant were to file a Rule
12 motion on March 18, Plaintiff’s response
would be due on April 1, 2025.

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10
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Proposed New Deadline

The Parties stipulate that the deadline for
Plaintiff’s Response will be moved to April 15,
20251

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IT IS SO STIPULATED.
15
MCLETCHIE LAW

LEWIS BRISBOIS BISGAARD & SMITH LLP

DATED this 10th, March, 2025.

DATED this 10th, March, 2025.

By: /s/ Margaret A. McLetchie_______
Margaret A. McLetchie, Esq.
Leo S. Wolpert, Esq.
McLETCHIE LAW
602 South Tenth Street
Las Vegas, Nevada 89101

By: /s/ Ellen Jean Winograd__________________
Ellen Jean Winograd, Esq.
Philip J. Tacason, Esq.
LEWIS BRISBOIS BISGAARD & SMITH LLP
5555 Kietzke Lane, Suite 200
Reno, Nevada 89511

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Attorneys for Defendant JACK JUAN

Attorneys for Plaintiff JACQUELINE
NICHOLS

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ORDER

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IT IS SO ORDERED.

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_____________________________________
United States Magistrate Judge
Dated: March 11, 2025

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Plaintiff’s position is that any motion to dismiss practice should be stayed until after the Court
resolves Plaintiff’s Motion to Remand (ECF No. 7) in no small part to save on attorney’s fees and
28 costs.
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LEWIS

BRISBOIS

1

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

153899935.1

2