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Barcelon v. Landforce Corp.

United States District Court, D. Nevada

January 7, 2020

ROBERT BARCELON, an individual Plaintiff,
v.
LANDFORCE CORPORATION Individually; ALBERT LEON HARRIS, Individually; DOES I-X and ROE CORPORATIONS I-X, inclusive, Defendants.

          STOVALL & ASSOCIATES ROSS H. MOYNIHAN, ESQ. Attorney for Plaintiffs

          LESLIE MARK STOVALL, ESQ. Attorney for Plaintiff

          PLAINTIFF'S UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO DEFENDANTS' THREE MOTIONS FILED WITH THE COURT AS DOCUMENTS 45, 46 AND 47 (FIRST REQUEST)

          DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE

         COMES NOW Plaintiff, by and through his attorneys, STOVALL & ASSOCIATES, and hereby files his Motion to Extend Time to respond to Defendants' three motions filed on December 23, 2019 as documents 45, 46, and 47 from January 6, 2020 to January 13, 2020, specifically:

         1. Defendants Motion to Extend the Current Discovery Deadlines Pursuant to LR IA 6-1 and LR II 26-4 (Fifth Request) (Doc# 45);

         2. Motion to Compel Discovery Pursuant to FED R CIV P 37 (A) (4) and Local Rule 26-7 or in the Alternative Motion to Strike Plaintiff's Designation of Expert Chris Reyes (Doc#46); and

         3. Motion to Compel Discovery Pursuant to FED R CIV P 37 (A) (4) and Local Rule 26-7 or in the Alternative Motion to Strike Plaintiff's Designation of Expert Chris Reyes (Doc#47).

         This motion is based upon the pleadings and papers on file herein, the Memorandum of Points and Authorities attached hereto, and any oral argument this Court may entertain at the hearing of this Motion.

         DECLARATION OF PLAINTIFF'S COUNSEL IN SUPPORT OF PLAINTIFF'S MOTION TO EXTEND TIME TO RESPOND TO DEFENDANTS' MOTIONS

         ROSS MOYNIHAN, declares and states as follows:

         1. I am an associate attorney at the Law Office of Stovall & Associates, counsel for Plaintiff, and am licensed to practice law in the State of Nevada.

         2. On December 23, 2019, defendants' filed three motions with oppositions due on January 6, 2020.

         3. On January 6, 2020, my office contacted defendants' counsel, Mr. Mills, who agreed to provide plaintiff's counsel with a one week extension to January 13, 2020 to file oppositions to the motions.

         4. Plaintiff's need for the extension is related to family commitments over the holiday season that prevented plaintiff's counsel from being ...


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