STIPULATION AND ORDER TO EXTEND PLAINTIFF'S RESPONSE TO DEFENDANT STEVEN GRIERSON'S MOTION TO DISMISS

ANDREW P. GORDON, District Judge.

Pursuant to LR 6-1, Plaintiff, Jacquelynn Nickler, by and through her counsel of record Cal J. Potter, III, Esq. and C. J. Potter, IV, Esq. of Potter Law Offices; Defendant, Steven D. Grierson, by and through his counsel of record Frederick J. Perdomo, Deputy Attorney General; and Defendants, Clark County and Kathleen Lambermont, by and through their counsel of record, Robert. W. Freeman, Esq. and Cayla Witty, Esq. of Lewis Brisbois Bisgaard & Smith, hereby stipulate and request that the scheduled date of filing of Plaintiff's Response to Defendant Steven Grierson's Motion to Dismiss [doc. 12] and Joinder [doc. 18], currently due on Friday, March 6, 2015, be extended twenty (20) days up to and including Thursday, March 26, 2015.

Plaintiff submits that good cause exists for this extension as Plaintiff's counsel, in addition to working on this response, has been preparing a post-conviction writ that cannot be extended, had three (3) depositions and four (4) day-long mandatory settlement conferences, in addition to other deadlines and appearances since the time Defendant filed his Motion. Additionally, next week, Plaintiff's counsel has five (5) depositions and numerous criminal appearances.

Based upon the foregoing, the parties request that this Court order the time for the Plaintiff to file her response to the Motion to Dismiss [doc. 12] and Joinder [doc. 18] to Thursday, March 26, 2015. The parties also request that this Court provide a concomitant enlargement of time for the Defendant's Reply thereto.

This is the first request for enlargement of time is made in good faith and not for the purposes of delay.

APPROVED AS TO FORM AND CONTENT.

ORDER

IT IS SO ORDERED.