Friedman v. United States of America

Opinion

LisA A. RASMUSSEN, ESQ. Nevada Bar No. 7491 2 || LAW OFFICE OF LISA RASMUSSEN, P.C. 601 South 10" Street, Suite #100 3 || Las Vegas, NV 89101 Tel. (702) 471-1436 Fax. (702) 489-6619 5 Email: Lisa@LRasmussenLaw.com 6 || MELANIE A. HILL, Esq. Nevada Bar No. 8796 7 || MELANIE HILL LAW PLLC 520 S. 7 Street, Suite A 8 || Las Vegas, NV 89101 Tel. (702) 362-8500 9|| Fax. (702) 362-8505 10 Email: Melanie@MelanieHillLaw.com 11 || Attorneys for Plaintiff Scott Friedman 12 15 16 || SCOTT FRIEDMAN, an individual, Case No. 2:18-CV-000857-JCM-VCF 17 Plaintiff, 18 JOINT MOTION TO EXTEND v. PLAINTIFF’S DEADLINE TO OPPOSE 19 DEFENDANT UNITED STATE’S UNITED STATES OF AMERICA; et. al., MOTION TO DISMISS [ECF No. 199] 20 AND DEFENDANT UNITED STATE’S Defendants. DEADLINE TO FILE ITS REPLY 22 (Second Request) 23 24 25 Counsel for Plaintiff, Melanie A. Hill of Melanie Hill Law PLLC and counsel for the Unite 26 States, Greg Addington, hereby jointly move to extend Plaintiffs deadline to oppose the Unit States’ Motion to Dismiss [ECF No. 199] from the current deadline of October 10, 2019 to Octob 28 14, 2019. The parties further jointly move to extend the United States’ deadline from the curre

1 deadline of October 18, 2019 to October 23, 2019. This is the second request to extend the □□□□□□□ 2 due to counsel for Plaintiffs progressing illness into pneumonia. 3 4 This Joint Motion is being filed and these extensions are being requested due to the □□□□□□□□□□ 5 of counsel due to her illness and not for purposes of delay. Plaintiff's counsel’s illness that h 6 || progressed into pneumonia has kept her out of work again this week due to its severity and the strot 7 || medication that counsel in taking also makes it difficult for her to draft the response. The parties har 8 || also agreed to extend the United States’ Reply deadline for an additional day to allow couns 9 || additional time to respond and in light of the fact that Plaintiff will be filing his opposition on tl 10 || Columbus Day federal holiday on October 14, 2019 and as a result the United States’ Reply deadlit is being extended to October 23, 2019. 12 The requested relief is not for purposes of delay, but to allow for the availability of couns 1 3 due to counsel’s severe illness. 14 DATED this 10" day of October, 2019. 15 17 United States Attorney MELANIE HILL LAW PLLC 18 By: /s/ Gregory Addington By: /s/ Melanie A. Hill Assistant United States Attorney Nevada Bar No. 8796 20 Nevada Bar No. 6875 Attorneys for Plaintiff Scott Friedman Attorneys for Defendant United States 21 of America 22 Dated October 11, 2019. 25 26 Bitdtiad © Atal Wun 27 (JAMS C. MAHAN UNITED STATES DISTRICT COURT JUDGE