Hill v. Petco Animal Supplies Stores, Inc. ( 2023 )

1 JOSHUA A. SLIKER, ESQ. Nevada Bar No. 12493 2 JACKSON LEWIS P.C. 3 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 4 Telephone: (702) 921-2460 Facsimile: (702) 921-2461 5 Email: joshua.sliker@jacksonlewis.com 6 Attorney for Defendant Petco Animal Supplies Stores, Inc. 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 KISHA HILL, Case No.: 2:23-cv-01002-RFB-VCF 11 Plaintiff, STIPULATION AND ORDER 12 EXTENDING TIME FOR DEFENDANT vs. TO RESPOND TO PLAINTIFF’S 13 PETCO ANIMAL SUPPLIES STORES, INC., COMPLAINT (ECF No. 1-1) 14 a Foreign Corporation Licensed to do Business in Nevada, (FIRST REQUEST) 15 Defendant. 16 Defendant Petco Animal Supplies Stores, Inc. (“Petco” Or “Defendant”), by and through its 17 counsel of record, the law firm of Jackson Lewis P.C., and Plaintiff Kisha Hill (“Plaintiff”), by and 18 through her counsel of record, the Law Office of Mary F. Chapman, Ltd., hereby stipulate and agree 19 to extend the time for Defendant Petco to file its response to Plaintiff’s Complaint (ECF No. 1-1) 20 up to and including July 28, 2023 based on the following: 21 1. This is the first stipulation to extend the time for Defendant to respond to Plaintiff’s 22 Complaint. 23 2. Defendant was served with the Summons and Complaint on June 8, 2023 and 24 removed the case to this Court on June 29, 2023 (ECF No. 1), making Defendant’s response to 25 Plaintiff’s Complaint currently due on July 6, 2023. 26 3. Defendant asserts that Plaintiff and Defendant are party to a written agreement 27 1 are subject to resolution by final and binding arbitration. 2 4. The parties have agreed to extend the deadline for Defendant to file its response to 3 the Complaint to July 28, 2023 to allow Plaintiff sufficient time to evaluate Defendant’s 4 information and request. Plaintiff’s counsel will be out of the office from July 6 to July 16 and will 5 also need time to consult with Plaintiff and her co-counsel. 6 5. The parties believe these circumstances constitute good cause for granting an 7 extension to permit the parties to explore whether they can avoid motion practice related to the 8 arbitration issue, conserving judicial resources. See Fed. R. Civ. P. 6(b)(1). 9 6. The parties are not waiving, relinquishing, or otherwise impairing any claim, 10 defense, argument, or other right they may have by virtue of entering into this Stipulation. Szanto 11 v. Marina Marketplace 1, LLC, No. 3:11-cv-00394-RCJ-VPC, 2013 U.S. Dist. LEXIS 168028, at 12 *10 (D. Nev. Nov. 26, 2013). 13 Dated this 5th day of July, 2023. 14 LAW OFFICES OF MARY F. CHAPMAN, JACKSON LEWIS P.C. LTD. 15 16 /s/ Mary F. Chapman /s/ Joshua A. Sliker MARY F. CHAPMAN, ESQ. JOSHUA A. SLIKER, ESQ 17 Nevada Bar No. 6591 Nevada Bar No. 12493 8440 W. Lake Mead Blvd., Suite 203 300 S. Fourth Street, Suite 900 18 Las Vegas, Nevada 89128 Las Vegas, Nevada 89101 19 Attorneys for Plaintiff Kisha Hill Attorneys for Defendant 20 Petco Animal Supplies Stores, Inc. 21 ORDER 22 IT IS SO ORDERED. 23 __________________________ 24 United States District Judge / 25 United States Magistrate Judge 26 Date: ___7_-_5_-2_0_2_3_____________ 4853-8212-3886, v. 2 27