Filed: Aug. 16, 2019
Latest Update: Aug. 16, 2019
Summary: STIPULATION AND ORDER EXTENDING TIME TO FILE OPPOSITION TO NATIONAL RECOVERIES, INC.'S MOTION FOR SUMMARY JUDGMENT [Dkt. 32] (First Request) RICHARD F. BOULWARE, II , District Judge . IT IS HEREBY STIPULATED AND AGREED between Plaintiff, Jonnah Garcia ("Garcia), and Defendant, National Recoveries, Inc. ("NRI") (collectively referred to as the "Parties"), by and through their respective attorneys of record, and subject to the approval of the Court, that Plaintiff's deadline to file her Opp
Summary: STIPULATION AND ORDER EXTENDING TIME TO FILE OPPOSITION TO NATIONAL RECOVERIES, INC.'S MOTION FOR SUMMARY JUDGMENT [Dkt. 32] (First Request) RICHARD F. BOULWARE, II , District Judge . IT IS HEREBY STIPULATED AND AGREED between Plaintiff, Jonnah Garcia ("Garcia), and Defendant, National Recoveries, Inc. ("NRI") (collectively referred to as the "Parties"), by and through their respective attorneys of record, and subject to the approval of the Court, that Plaintiff's deadline to file her Oppo..
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STIPULATION AND ORDER EXTENDING TIME TO FILE OPPOSITION TO NATIONAL RECOVERIES, INC.'S MOTION FOR SUMMARY JUDGMENT [Dkt. 32]
(First Request)
RICHARD F. BOULWARE, II, District Judge.
IT IS HEREBY STIPULATED AND AGREED between Plaintiff, Jonnah Garcia ("Garcia), and Defendant, National Recoveries, Inc. ("NRI") (collectively referred to as the "Parties"), by and through their respective attorneys of record, and subject to the approval of the Court, that Plaintiff's deadline to file her Opposition to NRI's Motion for Summary Judgment [Dkt. 32], filed on July 26, 2019, is hereby extended up to and including August 26, 2019;
Plaintiff received the transcripts from the July 31, 2019 depositions today and requires a brief extension to review these materials to adequately respond to the pending Motion for Summary Judgment;
The Parties have also been in settlement discussions regarding this matter and the additional time will permit these discussions to continue without expending unnecessary fees and costs.
This is the Parties first request for an extension of this deadline and is not made for the purpose of delay or bad faith.
Respectfully Submitted.
Dated: August 15, 2019 Dated: August 15, 2019
LAW OFFICE OF ALVERSON TAYLOR & SANDERS
KEVIN L. HERNANDEZ
/s/ Kevin L. Hernandez /s/ Trevor Waite
Kevin L. Hernandez, Esq. Kurt R. Bonds, Esq.
Nevada Bar No. 12594 Nevada Bar No. 6228
8872 S. Eastern Avenue, Suite 270 Trevor Waite, Esq.
Las Vegas, Nevada 89123 Nevada Bar No. 13779
kevin@kevinhernandezlaw.com 6605 Grand Montecito Parkway, Suite 200
Attorney for Plaintiff Las Vegas, NV 89149
efile@alversontaylor.com
Attorneys for National Recoveries, Inc
IT IS SO ORDERED.
