PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO THE MOTION TO DISMISS (FIRST REQUEST)

ANDREW P. GORDON, District Judge.

Pursuant to Federal Rule of Civil Procedure ("FRCP") 6(b)(1)(A), Plaintiff respectfully requests that the Court extend by 7-days, or until October 2, 2015, the time within which Plaintiff must respond to the motion to dismiss filed by Defendant Brandee Chambers. Plaintiff's response is currently due on September 25, 2015. This is Plaintiff's first request for extension of time for the purpose set forth herein.

In support of this motion, Plaintiff relies upon the memorandum of points and authorities set forth below.

MEMORANDUM OF POINTS AND AUTHORITIES

Federal Rule of Civil Procedure 6(b)(1)(A) permits a party to extend a deadline prior to its expiration "for good cause."

Here, good cause exists to extend the current deadline for responding to the pending dispositive motion. Undersigned counsel commenced drafting a response to the motion to dismiss but unfortunately has not been able to complete it within the current deadline. During the past three days, undersigned counsel was involved with the taking of several depositions and discovery related issues in another civil matter pending in Clark County District Court. Undersigned counsel's competing case commitments prevented him from devoting sufficient time to the completion of a response. A short one week extension, however, will provide reasonable time for Plaintiff's counsel to complete and file a response to Defendant Brandee Chambers' motion to dismiss.

CONCLUSION

Plaintff, by and through counsel, respectfully requests that the Court grant this motion.