Ulloa v. Nevada Gold Mines LLC

Filing 44

ORDER granting ECF No. 43 Stipulation : Response to ECF No. 40 Motion due by 8/12/2022. Signed by Magistrate Judge Craig S. Denney on 8/1/2022. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:21-cv-00495-RCJ-CSD Document 44 Filed 08/01/22 Page 1 of 2

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JAMES P. KEMP, ESQ.
Nevada Bar No. 6375
KEMP & KEMP
7435 W. Azure Dr., Suite 110
Las Vegas, Nevada 89130
[phone]/[phone] fax
[e-mail]
Attorney for Plaintiff JUAN ULLOA

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Plaintiff,

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CASE NO.: 3:21-cv-495-RCJ-CSD

JUAN ULLOA,

vs.

NEVADA GOLD MINES, a Delaware
9 Limited Liability Company,
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Defendant.

STIPULATION AND ORDER TO
EXTEND PLAINTIFF’S TIME TO
RESPOND TO DEFENDANT’S MOTION
FOR ENLARGEMENT OF TIME TO
RESPOND TO REQUESTS FOR
ADMISSIONS OR ALTERNATIVELY TO
WITHDRAW ADMISSIONS PURSUANT
TO FRCP 36(b) (ECF NO. 40)
(FIRST REQUEST)

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Defendant, Nevada Gold Mines, LLC (“Defendant” or “NGM”), by and through its

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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counsel of record, ANTHONY HALL and JONATHAN MCGUIRE of SIMONS HALL
JOHNSTON, and Plaintiff Juan Ulloa, (“Plaintiff”) by and through his counsel of record, J.P.

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KEMP of KEMP & KEMP, hereby stipulate and agree to extend the deadline for Plaintiff to file

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his Response to NGM’s Motion (ECF No. 40) that seeks an enlargement of time to respond to

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Requests for Admissions or alternatively to withdraw admissions pursuant to FRCP Rule 36(b).

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The response, currently due on July 29, 2022, will be extended by two (2) weeks to and

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including August 12, 2022.

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The reason for the extension, as Plaintiff’s counsel has informed Defense Counsel is that

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Plaintiff’s counsel had another significant briefing deadline due on July 29, 2022 and in the two

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weeks since Defendant’s motion was filed Plaintiff’s counsel has been tied up preparing for two

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party Rule 30(b)(6) depositions and a significant workers’ compensation appeal hearing. Also,

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Plaintiff’s counsel was out of the country on vacation until July 20, 2022 when he returned to

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the office. More time is needed to address the matters set forth in Defenant’s motion.

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Case 3:21-cv-00495-RCJ-CSD Document 44 Filed 08/01/22 Page 2 of 2

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This is the parties first request for an extension of time for Plaintiff to respond to Defendant’s
motion (ECF No. 40) and is made in good faith and not for the purpose of delay.

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DATED: July 29, 2022

DATED: July 29, 2022

KEMP & KEMP

SIMONS HALL JOHNSTON PC

/s/ James P. Kemp, Esq.
James P. Kemp, Esq.
KEMP & KEMP
7435 W. Azure Drive
Suite 110
Las Vegas, Nevada 89130
[e-mail]
Attorneys for Plaintiff

_ /s/ Jonathan A. McGuire, Esq._
Anthony L. Hall, Esq.
Jonathan A. McGuire, Esq.
SIMONS HALL JOHNSTON PC
690 Sierra Rose Drive
Reno, Nevada 89511
[e-mail]
[e-mail]
Attorneys for Defendant

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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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ecf@parsonsb
ORDER

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IT IS SO ORDERED.

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Dated: August 1, 2022

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_____________________________________________
UNITED STATES MAGISTRATE JUDGE

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