John A. Hunt
Nevada Bar No. 1888
CLARK HILL
3800 Howard Hughes Parkway
Suite 500
Las Vegas, NV 89169
702-862-83300
Email: jhunt@clarkhill.com Andrew Z. Tapp
Florida Bar No. 68002
Pro Hac Vice
METROPOLITAN LAW GROUP, PLLC
1971 W. Lumsden Road, #326
Brandon, Florida 33511-8820
813-228-0658
Email: Andrew@Metropolitan.Legal
PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
The Plaintiffs, DASHMESH ENTERPRISES, INC. a Nevada Corporation d/b/a YOUR STOP, RAVINDER S. GREWAL, an Individual, and RAJWANT K. GREWAL, an individual, by and through their undersigned counsel, and hereby respectfully move the Court for an enlargement of time to file its reply brief in opposition to Defendant's Motion For Summary Judgment filed on November 23, 2020 (Doc. 37), from January 4, 2021 up to and including January 6, 2021, and respectfully moves this Honorable Court for an entry of the attached proposed Order. CASE HISTORY & BACKGROUND
1. On November 23, 2020, Defendant's filed their Motion for Summary Judgment (Doc. 37).
2. Local Rule 7-2(b) provides that the Plaintiffs Response to the Defendant's Motion for Summary Judgment was due December 14, 2020.
3. On November 25, 2020, the Plaintiffs filed an Unopposed Motion for Enlargement of time to File Reply Brief in Opposition to Defendant's Motion for Summary Judgment from December 14, 2020 to January 4, 2021 (Doc.38), which was granted by this Court on December 1, 2020 (Doc. 39).
4. Since the Plaintiffs' motion, intervening issues have caused problems necessitating a brief extension in the Plaintiffs' time for response. Most significantly of these problems includes the unexpected and emergency hospitalization of one of the undersigned's paralegals in evening hours of January 3rd, 2021, resulting in a number of additional deadlines for January 4th that need to be completed. In addition thereto, the undersigned received more than thirty administrative deadlines (for which the undersigned had ten (10) days' notice to compile responses and administrative briefs) were unexpectedly due between December 28th, 2020 and January 1st, 2021.
5. In the interests of providing the Court a more well-organized filing in response to the Government's summary judgment motion, the Plaintiffs' counsel believes that a two (2) day extension to January 6th, 2021 is necessary to complete the response to the Defendant's Motion for Summary Judgment.
6. The undersigned's office has conferred with the Defendant's counsel regarding this extension and was advised that the Defendant has no objection to the requested extension.
7. This is the Plaintiffs' second motion to extend time for filing their response in opposition to the Defendant's Motion for Summary Judgment.
8. As such, Plaintiffs request entry of an order granting them an extension up to and including January 6, 2021, an additional two (2) days, within which to file and serve their Response to the Defendant's Motion for Summary Judgment.
9. The Plaintiffs do not believe the requested extension will result in undue delay of this matter.
WHEREFORE, for the reasons set forth above, Plaintiffs, Dashmesh Enterprises, Inc., a Nevada Corporation d/b/a Your Stop, Ravinder S. Grewal, an Individual, Rajwant K. Grewal, an individual, respectfully request this Court enter an order granting the unopposed motion, and granting up to and including January 6, 2021 for the Plaintiffs' Response to the Defendant's Motion for Summary Judgment. Dated: January 4, 2021
Respectfully submitted,
By: /s/ Andrew Z. Tapp
Andrew Z. Tapp (FBN 68002)
Pro Hac Vice
METROPOLITAN LAW GROUP, PLLC
1971 W. Lumsden Road, #326
Brandon, Florida 33511-8820
Telephone: (813) 228-0658
Facsimile: (813) 330-3129
Email: andrew@metropolitan.legal
And
JOHN A. HUNT, ESQ.
Nevada Bar No. 1888
CLARK HILL
3800 Howard Hughes Parkway
Suite 500
Las Vegas, NV 89169
Telephone: (702) 862-8300
Facsimile: (702) 862-840
Email: jhunt@clarkhill.com
COUNSEL FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 4, 2021, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following:
Patrick A. Rose, Esq.
Patrick.Rose@usdoj.gov
/s/ Andrew Z . Tapp
Andrew Z. Tapp (FBN 68002)
Pro Hac Vice
ORDER GRANTING PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF IN OPPOSITION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT
(Docket No. 40)
Pending before the Court is Plaintiffs' Unopposed Motion for Enlargement of Time to File Reply Brief in Opposition to Defendant's Motion for Summary Judgment, Docket No. 40. The Court having reviewed the unopposed motion therefore GRANTS the motion, Docket No. 40. The Plaintiffs, Dashmesh Enterprises, Inc., a Nevada Corporation d/b/a Your Stop, Ravinder S. Grewal, an Individual, and Rajwant K. Grewal, an individual may file their reply brief in opposition to Defendant's Motion for Summary Judgment on or before January 6, 2021.
IT IS SO ORDERED.
Dated this 4 day of January, 2021.
/s/_________
Gloria M. Navarro, District Judge
UNITED STATES DISTRICT COURT