Herb Hallman Chevrolet, Inc. v. General Motors LLC

Filing 70

ORDER granting ECF No. 69 MOTION to Extend Time (First Request) re ECF No. 68 Motion for Summary Judgment. Responses due by 10/4/2024. Signed by Chief Judge Miranda M. Du on 9/24/2024. (Copies have been distributed pursuant to the NEF - GA)

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KENNETH E. LYON III, ESQ.
[e-mail]
Nevada Bar No. 7071
LAW OFFICES OF KENNETH E. LYON, III
432 Court Street
Reno, Nevada 89501
Telephone: [phone]
RICHARD M. SOX, ESQ.,
NICHOLAS A. BADER, ESQ.,
JEREMIAH HAWKES, ESQ.
[e-mail]
[e-mail]
[e-mail]
(Pro Hac Vice)
BASS SOX MERCER
2822 Remington Green Circle Tallahassee, Florida 32308
Telephone: [phone]
Attorneys for Herb Hallman Chevrolet, Inc.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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HERB HALLMAN CHEVROLET, INC.,
D.B.A. CHAMPION CHEVROLET,

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Plaintiff,

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vs.

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GENERAL MOTORS LLC,

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Defendant

Case No.: 3:22-CV-00447-MMD-CLB

ORDER GRANTING PLAINTIFF’S
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO RESPOND
TO DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT (FIRST
REQUEST)

Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), and Local Rules IA 6-1(a)

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and IA 6-2, Plaintiff Herb Hallman Chevrolet, Inc., d/b/a Champion Chevrolet (“Plaintiff”

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or “Champion”), hereby files this Unopposed Motion for Extension of Time to Respond

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to Defendant’s Motion for Summary Judgment (ECF No. 68), filed by Defendant, General
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Motors, LLC (“Defendant” or “GM”) on September 9, 2024. This is the first request for an
extension of this deadline. In support thereof, Plaintiff states as follows:
1.

On September 9, 2024, Defendant filed its Motion for Summary Judgment

(ECF No. 68).
2.

Plaintiff’s response to the same is presently due on September 30, 2024.

3.

As of the filing of the instant Motion, a dangerous weather system has

developed in the Gulf of Mexico.
4.

The weather system is expected to develop into Hurricane Helene and

make landfall in the Big Bend region of Florida’s panhandle—where counsel for Plaintiff
is located—between late Thursday, September 29, 2024 and Friday, September 30, 2024.
5.

In preparation for Helene’s impending landfall, Plaintiff’s counsel’s

Tallahassee, Florida office will likely be closed from at least Thursday, September 29, 2024
through Friday, September 30, 2024.
6.

As such, Plaintiff respectfully requests that this Honorable Court enter an

order extending Plaintiff’s deadline to respond to Defendant’s Motion for Summary
Judgment by one (1) week.
7.

In accordance with Federal Rule of Civil Procedure 6(b)(1)(A) and LR IA 6-

1(a), Plaintiff submits that good cause exists to extend the deadline to respond.
8.

Such request is not made for the purposes of delay; this is Plaintiff’s first

request for an extension of this deadline; and no other deadlines in the case schedule will
be disturbed by granting such relief.
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WHEREFORE, Plaintiff requests that the Court extend the time until October 4,
2024, for Plaintiff to respond to GM’s Motion for Summary Judgment.
LOCAL RULE IA-3 DECLARATION OF CONFERRAL

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The undersigned conferred with counsel for Defendant regarding the requested

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extension via electronic mail on September 23, 2024. On the same day, counsel for GM

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advised that GM consents to a one-week extension of Plaintiff’s deadline to respond to
GM’s Motion for Summary Judgment.

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Respectfully Submitted,

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/s/Nicholas A. Bader
KENNETH E. LYON, III
Nevada Bar No. 7071
LAW OFFICES OF KENNETH E.
LYON, III
432 Court Street
Reno, Nevada 89501
BASS SOX MERCER
Nicholas A. Bader (pro hac vice)
Jeremiah M. Hawkes (pro hac vice)
2822 Remington Green Circle
Tallahassee, Florida 32308

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IT IS SO ORDERED.

ORDER

UNITED STATES DISTRICT JUDGE
DATED: September 24, 2024

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CERTIFICATE OF SERVICE
I certify that a true copy of the above was filed using the Court’s CM/ECF
system and thus served upon counsel for each party on September 24, 2024
/s/Nicholas A. Bader
Nicholas A. Bader

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