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Dr. Vicki Mazzorana, M.D v. Emergency Physicians Medical Group

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA


April 30, 2013

DR. VICKI MAZZORANA, M.D.,
PLAINTIFF,
v.
EMERGENCY PHYSICIANS MEDICAL GROUP, INC., ET. AL.,
DEFENDANTS.

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT'S MOTION TO DISMISS

(First Request)

Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A) and the Court's Local Rule 7-2, Plaintiff, Dr. Vicki Mazzorana, M.D., respectfully requests that the Court extend, to and until May 8, 2013, the current deadline for responding to Defendants' motion to dismiss. This is Plaintiff's first request for extension of time. Plaintiff's response to Defendants' pending dispositive motion is currently due on April 29, 2013.

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) provides that "[w]hen an act may or must be done within a specified time, the court may, for good cause, extend the time with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires . . .." It is within a trial court's sound discretion to determine whether to grant an extension of time. Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1258 (9th Cir. 2012). In this case, "good cause" exists for the requested extension of time.

Lead counsel for Plaintiff, Ruth L. Cohen, has been suffering from recent illness*fn1 that has prevented her from devoting the time necessary to meeting a number of deadlines in her cases, including the one pending in this case. While it was anticipated that Ms. Cohen would currently be preparing a response to Defendants' motion to dismiss, she suffered an unfortunate relapse of her illness that has prevented her from devoting the time necessary to accomplishing the foregoing task. Despite his own heavy caseload,*fn2 undersigned counsel will be required to address the numerous deadlines in Ms. Cohen's cases, including taking responsibility for meeting the deadlines in this and many other cases.

In light of the foregoing, undersigned counsel will need additional time to prepare and file Dr. Mazzorana's response to the pending motion to dismiss. For instance, apart from drafting the actual response, undersigned counsel will need to familiarize himself with Defendants' dispositive motion. An additional eleven days will be necessary to accomplish this task. Indeed, in addition to preparing the response, undersigned counsel will also be balancing other competing case commitments during this time frame. However, an additional eleven days should provide adequate time for undersigned counsel to file an appropriate response to Defendants' motion to dismiss.

CONCLUSION

In light of the foregoing, Plaintiff, by and through undersigned counsel, respectfully requests that the Court provide her with an additional eleven days, to and until May 8, 2013, file a response to the pending dispositive motion.

Respectfully submitted, /s/ Paul S. Padda Ruth L. Cohen, Esq. Paul S. Padda, Esq. COHEN & PADDA, LLP 4240 West Flamingo Rd., #220 Las Vegas, Nevada 89103 Tele: (702) 366-1888 Fax: (702) 366-1940 Web: caplawyers.com Attorneys for Plaintiff

Dated: April 24, 2013

IT IS SO ORDERED: Plaintiff's request for an extension of time to respond to the pending dispositive motion is hereby granted. Plaintiff's response shall be due on or before May 8, 2013.

UNITED STATES MAGISTRATE JUDGE DISTRICT

CERTIFICATE OF SERVICE

In compliance with the Court's Local Rules, the undersigned hereby certifies that on April 24, 2013 a copy of the foregoing document, "PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS" was served (via the Court's CM/ECF system) upon counsel of record for Defendants.

/s/ Paul S. Padda Paul S. Padda, Esq. Cohen & Padda, LLP Las Vegas, Nevada


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