Myung v. Colonial Van Lines Inc.

• Court: District Court, D. Nevada
• Decided: June 30, 2025
• Docket: 2:24-cv-02182
• Status: Unknown

Opinion

Nevada Bar No. 11587 2 HAMILTON LAW 5125 S. Durango Dr. 3 Las Vegas, NV 89113 4 (702) 818-1818 (702) 974-1139 fax 5 ryan@hamlegal.com 6 Attorney for Plaintiff, Jin Myung and Derek Kinoshita 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 JIN MYUNG, an individual; DEREK Case No.: 2:24-cv-02182-CDS-NJK KINOSHITA, an individual; 11 STIPULATION TO EXTEND 12 Plaintiffs TIME TO FILE OPPOSITIONS TO DEFENDANT COLONIAL 13 v. VAN LINES’ MOTION FOR PARTIAL SUMMARY 14 RESPECT, LLC, a Nevada limited JUDGMENT AND MOTION liability company; COLONIAL VAN FOR SUMMARY JUDGMENT 15 LINES d/b/a MOVING VAN LINES, 16 a foreign corporation; [ECF No. 32] 17 Defendants 18 19 20 21 Plaintiff JIN MYUNG and Plaintiff DEREK KINOSHITA (collectively 22 “Plaintiffs”), by and through their counsel RYAN A. HAMILTON, ESQ., of 23 HAMILTON LAW, and Defendant COLONIAL VAN LINES (hereafter “CVL”), 24 by and through its counsel CRAIG D. SLATER, ESQ., of LUH & ASSOCIATES, 25 stipulate and agree to extend the current deadline of June 30, 2025, for 1 || Plaintiffs to file their oppositions to Defendant CVL’s Motion for Partial 2 || Summary Judgment (ECF No. 30) and Motion for Summary Judgment (ECF 3 || No. 31), by four days to and including, July 4, 2025. 4 1. On June 9, 2025, Defendant CVL filed a Motion for Partial 5 || Summary Judgment (ECF No. 30). 6 2. OnJune 9, 2025, Defendant CVL filed a Motion for Summary 7 || Judgment. 8 3. Federal Rules of Civil Procedures 6(b) and Local Rule IA 6-1 9 || impose a good cause standard to extend the deadline file an Opposition. 10 || “Good cause is a non-rigorous standard that has been construed broadly 11 || across procedural and statutory contexts.” Ahanchian v. Xenon 12 || Pictures, Inc., 624 F.3d 1253, 1259 (9th Cir. 2010). 13 4. Good cause exists to extend the deadline for Plaintiffs to file their 14 || Opposition by four days as counsel for Plaintiffs has been locked into trial 15 || for the last two weeks and trial is continuing into next week. In addition, 16 |! counsel for Plaintiffs has a Ninth Circuit deadline that will not allow for 17 || further extensions. 18 19 20 21 22 23 24 25

1 5. Neither party will suffer any prejudice from an extension of time. 2 || DATED this 20th day of June 2025. DATED this 20th day of June 2025. ; /s/Ryan A. Hamilton /s/Craig D. Slater 4 ||Ryan A. Hamilton, Esq. Craig D. Slater, Esq. Nevada Bar No. 11587 Nevada Bar No. 8667 5 || HAMILTON LAW LUH & ASSOCIATES 5125 8S. Durango Dr. 8987 W. Flamingo Rd., Suite 100 6 | Las Vegas, NV 89113 Las Vegas, NV 89147 7 ||(702) 818-1818 (702) 367-8899 (702) 974-1139 (fax) (702) 384-8899 (fax) g ||ryan@hamlegal.com cluh@luhlaw.com 9 || Attorney for Plaintiff, Attorneys for Defendant, 10 Jin Myung and Derek Kinoshita Colonial Van Lines

IT IS SO ORDERED. 12 /, | / 13 Vf 14 15 UNIT 7 AT ISTRICT JUDGE 16 Dayle June 27, 2025 17 18 19 20 21 22 23 24 25