Reyes v. Keefe Group, LLC

Filing 6

ORDER granting ECF No. 5 Motion to Extend Time : Keefe Group, LLC answer/response to ECF No. 1 Complaint due by 3/5/2018. Signed by Magistrate Judge William G. Cobb on 2/7/2018. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:18-cv-00004-LRH-WGC Document 5 Filed 02/07/18 Page 1 of 4

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MICHELLE D. ALARIE, ESQ.
Nevada Bar No. 11894
ARMSTRONG TEASDALE LLP
3770 Howard Hughes Parkway, Suite 200
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702.878.9995
[e-mail]
DANIEL O’TOOLE, ESQ. (will comply with LR IA 11-2 within 45 days)
Missouri Bar No. 38051
ARMSTRONG TEASDALE LLP
7700 Forsyth Boulevard, Suite 1800
St. Louis, Missouri 63105
Telephone: [phone]
Facsimile: 314.621.5065
[e-mail]
Attorneys for Defendant Keefe Commissary Network,
LLC

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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JOHANA REYES,

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Plaintiff,
vs.
KEEFE GROUP, LLC and DOE Defendants
I-X,
Defendants.

Case No.: 3:18-cv-00004-LRH-WGC
ORDER GRANTING
UNOPPOSED MOTION TO EXTEND
DEFENDANT’S DEADLINE TO RESPOND
TO COMPLAINT AND [PROPOSED]
ORDER
[FIRST REQUEST]

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Defendant Keefe Commissary Network, LLC (incorrectly identified in the Complaint as

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Keefe Group, LLC) (“Keefe”), by and through its counsel, Armstrong Teasdale LLP, hereby

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respectfully requests an extension of Keefe’s deadline to respond to the Complaint from February 7,

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2018, to March 5, 2018. Plaintiff Johana Reyes (“Reyes”) has consented to the requested extension.

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This is the first request to extend this particular deadline.

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On January 4, 2018, Reyes filed her Complaint against Keefe alleging claims for sexually

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hostile work environment, disability discrimination, and retaliation. See ECF No. 1. The Summons
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Case 3:18-cv-00004-LRH-WGC Document 5 Filed 02/07/18 Page 2 of 4

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and Complaint were served on Keefe on January 17, 2018. See ECF No. 4. Therefore, pursuant to

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Rule 12(a) of the Federal Rules of Civil Procedure, Keefe’s response to the Complaint is due on

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February 7, 2018.

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On February 5, 2018, undersigned counsel contacted Reyes’ counsel to discuss stipulating to

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extend Keefe’s response deadline. Reyes’ counsel agreed to continue Keefe’s answer deadline from

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February 7, 2018, to March 5, 2018. Counsels, however, were not able to agree on language for a

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stipulation, therefore, Keefe files this unopposed motion.

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Good cause for this extension exists. Counsel for Keefe was recently retained, and therefore,

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requires additional time to adequately review and consider this matter in anticipation of responding

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to the Complaint. This short extension will not prejudice any parties nor affect any current deadlines

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because this case is still in its infancy – no parties have answered the Complaint and a case

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management order had not been entered. This stipulation is entered into in good faith and is not

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intended to unduly delay the proceedings.

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Case 3:18-cv-00004-LRH-WGC Document 5 Filed 02/07/18 Page 3 of 4

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Accordingly, Keefe requests that an order be entered extending the deadline for Keefe to
respond to the Complaint from February 7, 2018, to March 5, 2018.

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Dated this 7th day of February, 2018.

ARMSTRONG TEASDALE, LLP

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By: /s/ Michelle D. Alarie________________
MICHELLE D. ALARIE, ESQ.
Nevada Bar No. 11894
3770 Howard Hughes Parkway, Suite 200
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702.878.9995
[e-mail]

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DANIEL O’TOOLE, ESQ.
Missouri Bar No. 38051
7700 Forsyth Boulevard, Suite 1800
St. Louis, Missouri 63105
[e-mail]

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Attorneys for Defendant Keefe Commissary
Network, LLC

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ORDER
IT IS SO ORDERED.
____________________________________
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE
DATED: February 7, 2018

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