Martin v. Smiths Food & Drug Centers, Inc. ( 2024 )

Nevada Bar #001107 2 POOJA KUMAR Nevada Bar #012988 3 COOPER LEVENSON, P.A. 3016 West Charleston Boulevard - #195 4 Las Vegas, Nevada 89102 (702) 366-1125 5 FAX: (702) 366-1857 jbusby@cooperlevenson.com 6 pkumar@cooperlevenson.com Attorneys for Defendant 7 SMITH’S FOOD & DRUG CENTERS, INC. 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 QUINTNEY MARTIN, an individual, Case No. 2:22-cv-00833-APG-DJA 11 Plaintiff, 12 vs. STIPULATION AND ORDER TO 13 SMITH’S FOOD & DRUG CENTERS, INC. EXTEND TIME TO FILE RESPONSE TO d/b/a SMITH’S FOOD AND DRUG, a foreign PLAINTIFF’S OBJECTION TO 14 corporation; DOES I through X; and ROE MAGISTRATE’S JUNE 20, 2024, ORDER ENTITIES I through X, (ECF No. 76) 15 Defendants. (Second Request) 16 17 IT IS HEREBY STIPULATED by and between Plaintiff QUINTNEY MARTIN and 18 Defendant SMITH’S FOOD & DRUG CENTERS, INC. by and through their respective counsel of 19 records that the deadline for Defendant to file its Response to Plaintiff’s Objection to Magistrate’s 20 June 20, 2024, Order and Report and Recommendation (ECF No. 76) be briefly extended by four (4) 21 additional days until July 30, 2024. This stipulation is entered into and made pursuant to LR IA 6-1 22 and LR 7-1 as a result of conflicts in the schedule of defense counsel, among other issues, which 23 make counsel unable to file their response on the current deadline of July 26, 2024. 24 Good cause exists for the very brief additional continuance from the original deadline, July 25 17, 2024, due to both health and family related issues of the handling attorney. Furthermore, lead 26 defense counsel is not presently located in the jurisdiction. 27 / / / 28 / / / 1 This extension is sought in order to allow defense counsel sufficient time to properly address and brief all issues raised in ECF No. 76. As held in this Court, the practicalities of life, such as an 3|| attorney’s conflicting professional engagements or personal commitments, including but not limited 4|| to illnesses or deaths, often necessitate an enlargement of time to comply with a court deadline. 5|| Morales v. McDaniel, No. 3:17-cv-00197-MMD-CBC, 2019 U.S. Dist. LEXIS 173103, at *4 (D. 6|| Nev. Oct. 3, 2019). The requesting party has acted diligently considering this request is timely and 7\| within the presently ordered deadline. /d. 8 IT IS SO STIPULATED. 9 DATED this 26" day of July, 2024. 10|| TANNER LAW FIRM COOPER LEVENSON, P.A 1] /s/ Jeffrey C. Gunn /s/ Ty M. Maynarich (Nevada Bar No. 014584) 12|| DAVID A. TANNER, ESQ. JERRY S. BUSBY, ESQ. Nevada Bar No. 08282 Nevada Bar No. 001107 13|| JEFFREY C. GUNN, ESQ. POOJA KUMAR, ESQ. Nevada Bar No. 015925 Nevada Bar No. 012988 14|| 7895 West Sunset Road — Suite 115 3016 West Charleston Boulevard - #195 Las Vegas, NV 89113 Las Vegas, Nevada 89102 15|| (702) 987-8888 (702) 366-1125 Attorneys for Plaintiff Attorneys for Defendant 16|| QUINTNEY MARTIN SMITH’S FOOD & DRUG CENTERS, INC. 17 18 19 IT IS SO ORDERED. Defendant’s response to ECF No. 76 is due by July 30, 2024. 20 21 22 Z- ANDREW P. GORDON 23 UNITED STATES DISTRICT JUDGE 24 25 DATE: July 29, 2024 26 27 28 ty