Shepherd v. Tesla, Inc.

Filing 6

ORDER granting 5 STIPULATION FOR EXTENSION OF TIME (First Request) re: 1 Petition for Removal. Response/Answer due 3/28/2025. Signed by Magistrate Judge Craig S. Denney on 3/11/2025. (Copies have been distributed pursuant to the NEF - GA)

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Deverie J. Christensen
Nevada State Bar No. 6596
JACKSON LEWIS P.C.
300 South Fourth Street, Suite 900
Las Vegas, Nevada 89101
Tel: [phone]
Email: [e-mail]
Attorney for Defendant
Tesla, Inc. fka Tesla Motors, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MALCOLM SHEPHERD,
Plaintiff,

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vs.

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Case No. 3:25-cv-00137-ART-CSD

TESLA, INC., (a.k.a. TESLA MOTORS, INC.)
a Delaware Corporation; DOES I-X; and, ROE
Business Entities I-X,

ORDER GRANTING
STIPULATION TO EXTEND
DEADLINE FOR DEFENDANTS
TO RESPOND TO PLAINTIFF’S
COMPLAINT
(FIRST REQUEST)

Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiff Malcolm Shepherd, (“Plaintiff”),

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by and through his counsel, Kemp & Kemp, and Defendant, Tesla, Inc. fka Tesla Motors, Inc.

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(“Defendant”), by and through their counsel, the law firm of Jackson Lewis P.C., that Defendant

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shall have an extension up to and including March 28, 2025, in which to file its response to

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Plaintiff’s Complaint. This Stipulation is submitted and based upon the following:
1.

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Plaintiff filed his Complaint on November 29, 2024 in the District Court, Clark

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County Nevada, Case No. A-24-907076-C.

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Defendant on or about February 14, 2025.
2.

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On March 7, 2025, the Defendant filed a Notice to Federal Court of Removal of

Civil Action from State Court, Case No. 3:25-cv-00137-ART-CSD.

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The Summons and Complaint were served on

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Defendant’s response to the Complaint, following removal, is due on March 14,

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Undersigned Defense Counsel represents Tesla Inc. in an unrelated arbitration case

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pending before JAMS and for which Plaintiff’s counsel represents the claimant in that arbitration

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case. Both Counsels are preparing for an arbitration hearing that begins on March 31, including

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meeting and conferring regarding exhibits, witnesses, objections, and other matters for which

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deadlines are fast approaching in the next two weeks.

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Accordingly, Undersigned Defense Counsel needs additional time to prepare a

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response to the complaint filed in this case, and requested Plaintiff agree to a two-week extension

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to March 28, 2025. Plaintiff has kindly agreed to the requested extension.

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Thus, the parties hereby stipulate to extend the deadline to March 28, 2025, for

Defendant to file its response to the Complaint.
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This is the first request for an extension of time for Defendant to file its response to

Plaintiff’s Complaint.

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8.

This Stipulation is made in good faith and not for the purpose of delay.

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9.

Nothing in this Stipulation and Order shall operate to waive, relinquish, or impair

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any claim, defense, objection, or right of any party in this case. Further, nothing in this Stipulation

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and Order shall be construed as an admission of or consent to the merit or validity of any claim,

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defense, objection, or right by any party in this case.

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Dated this 11th day of March, 2025.

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KEMP & KEMP

JACKSON LEWIS P.C.

/s/ James P. Kemp
James P. Kemp, Esq., Bar #6375
7435 W. Azure Drive, Ste. 110
Las Vegas, Nevada 89130

/s/ Deverie J. Christensen
Deverie J. Christensen, Bar # 6596
300 South Fourth Street, Suite 900
Las Vegas, Nevada 8910

Attorney for Plaintiff
Malcolm Shepherd

Attorney for Defendant
Tesla, Inc. fka Tesla Motors, Inc.

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ORDER

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IT IS SO ORDERED.

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United States Magistrate Judge

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Dated: March 11, 2025.
4907-6867-5110, v. 1

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