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)

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Case 3:21-cv-00495-RCJ-CSD Document 44 Filed 08/01/22 Page 1 of 2 1 2 3 4 JAMES P. KEMP, ESQ. Nevada Bar No. 6375 KEMP & KEMP 7435 W. Azure Dr., Suite 110 Las Vegas, Nevada 89130 (702) 258-1183/(702) 258-6983 fax jp@kemp-attorneys.com Attorney for Plaintiff JUAN ULLOA 5 6 Plaintiff, 7 8 CASE NO.: 3:21-cv-495-RCJ-CSD JUAN ULLOA, vs. NEVADA GOLD MINES, a Delaware 9 Limited Liability Company, 10 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) 11 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. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 13 14 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. 15 KEMP of KEMP & KEMP, hereby stipulate and agree to extend the deadline for Plaintiff to file 16 his Response to NGM’s Motion (ECF No. 40) that seeks an enlargement of time to respond to 17 Requests for Admissions or alternatively to withdraw admissions pursuant to FRCP Rule 36(b). 18 The response, currently due on July 29, 2022, will be extended by two (2) weeks to and 19 including August 12, 2022. 20 The reason for the extension, as Plaintiff’s counsel has informed Defense Counsel is that 21 Plaintiff’s counsel had another significant briefing deadline due on July 29, 2022 and in the two 22 weeks since Defendant’s motion was filed Plaintiff’s counsel has been tied up preparing for two 23 party Rule 30(b)(6) depositions and a significant workers’ compensation appeal hearing. Also, 24 Plaintiff’s counsel was out of the country on vacation until July 20, 2022 when he returned to 25 the office. More time is needed to address the matters set forth in Defenant’s motion. 26 /// 27 /// 28 1 Case 3:21-cv-00495-RCJ-CSD Document 44 Filed 08/01/22 Page 2 of 2 1 2 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. 3 4 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 JP@Kemp-attorneys.com 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 AHall@SHJNevada.com JMcGuire@SHJNevada.com Attorneys for Defendant 5 6 7 8 9 10 11 ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 13 14 ecf@parsonsb ORDER 15 16 IT IS SO ORDERED. 17 18 Dated: August 1, 2022 19 20 21 _____________________________________________ UNITED STATES MAGISTRATE JUDGE 22 23 24 25 26 27 28 2

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