Filed: Dec. 04, 2018
Latest Update: Dec. 04, 2018
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE PLAINTIFF'S OPPOSITION TO DEFENDANT CHRISTOPHER KLEMP'S SPECIAL MOTION TO DISMISS PURSUANT TO NRS 41,660 (NEVADA'S ANTI-SLAPP STATUTE) (Second Request) JENNIFER DORSEY , District Judge . COMES NOW Plaintiff, JAMES LESCINSKY, by and through his attorney of record MELVIN R. GRIMES, ESQ. of THE GRIMES LAW OFFICE, and Defendant, CHRISTOPHER KLEMP, by and through his Attorneys of Record, MARK E. FERRARIO, ESQ., KARA HENDRICKS ESQ., and BETHANY L. RA
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE PLAINTIFF'S OPPOSITION TO DEFENDANT CHRISTOPHER KLEMP'S SPECIAL MOTION TO DISMISS PURSUANT TO NRS 41,660 (NEVADA'S ANTI-SLAPP STATUTE) (Second Request) JENNIFER DORSEY , District Judge . COMES NOW Plaintiff, JAMES LESCINSKY, by and through his attorney of record MELVIN R. GRIMES, ESQ. of THE GRIMES LAW OFFICE, and Defendant, CHRISTOPHER KLEMP, by and through his Attorneys of Record, MARK E. FERRARIO, ESQ., KARA HENDRICKS ESQ., and BETHANY L. RAB..
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STIPULATION AND ORDER TO EXTEND TIME TO FILE PLAINTIFF'S OPPOSITION TO DEFENDANT CHRISTOPHER KLEMP'S SPECIAL MOTION TO DISMISS PURSUANT TO NRS 41,660 (NEVADA'S ANTI-SLAPP STATUTE)
(Second Request)
JENNIFER DORSEY, District Judge.
COMES NOW Plaintiff, JAMES LESCINSKY, by and through his attorney of record MELVIN R. GRIMES, ESQ. of THE GRIMES LAW OFFICE, and Defendant, CHRISTOPHER KLEMP, by and through his Attorneys of Record, MARK E. FERRARIO, ESQ., KARA HENDRICKS ESQ., and BETHANY L. RABE ESQ. of GREENBERG TRAURIG, and hereby stipulate and make joint application to extend the time for Plaintiff to file an Opposition to Defendant's Motion to Dismiss.
1. On November 9th 2018, the Defendant, Christopher Klemp, by and through his attorneys of record, Mark E. Ferrario, Esq., Kara Hendricks Esq., And Bethany L. Rabe Esq. filed a Special Motion to Dismiss Pursuant to NRS 41.660.
2. On November 15th 2018, Attorney Hendricks agreed to extend the due date for Plaintiff's Opposition to Plaintiff's Motion to Dismiss to December 3rd 2018.
3. On November 20th 2018, Counsel filed the Plaintiff's First Stipulation for Extension of Time to File Plaintiff's Opposition to Defendant Christopher Klemp's Special Motion to Dismiss.
4. On November 21st 2018, this Court entered an Order Granting Plaintiff's First Stipulation for Extension of Time to File Plaintiff's Opposition to Defendant Christopher Klemp's Special Motion to Dismiss, allowing Counsel until December 3rd 2018 to file the Plaintiff's Opposition.
5. On December 3rd 2018, the Parties met for an Early Neutral Evaluation Session before Magistrate Judge Cam Ferenbach.
6. Counsel will be unable to complete Plaintiff's Opposition to Defendant Christopher Klemp's Special Motion to Dismiss by the current due date, December 3rd 2018. Counsel requested by e-mail to Mark E. Ferrario, Esq., Kara Hendricks Esq., And Bethany L. Rabe Esq. for a second extension of time to file Plaintiff's Opposition to Defendant Christopher Klemp's Special Motion to Dismiss on December 3, 2018.
7. On December 3rd, Attorney Kara Hendricks agreed to extend the due date for Plaintiff's Opposition to Plaintiff's Motion to Dismiss to December 5th 2018.
8. This is the Second request for enlargement of time and it is made in good faith and not for purposes of delay.
ORDER
IT IS SO ORDERED this 4th day of December, 2018 that the parties' extension of time for the Plaintiff to file their Opposition to Defendant Christopher Kemp's Special Motion to Dismiss Pursuant to NRS 41.660 is hereby granted.
