Rafford Broadnax, an individual v. Lyft, Inc., a Delaware Company; et al.

• Court: District Court, D. Nevada
• Decided: December 19, 2025
• Docket: 2:25-cv-00190
• Status: Unknown

Opinion

KIRSTEN A. MILTON, ESQ. 1 Nevada Bar No. 14401 AMANDA PATANAPHAN, ESQ. 2 Nevada Bar No. 15080 3 JACKSON LEWIS P.C. 300 S. Fourth Street, Suite 900 4 Las Vegas, Nevada 89101 Telephone: (702) 921-2460 5 Email: kirsten.milton@jacksonlewis.com Email: amanda.patanaphan@jacksonlewis.com 6 7 Attorneys for Defendant Lyft, Inc. 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 RAFFORD BROADNAX, an individual, Case No. 2:25-cv-00190-APG-BNW 12 Plaintiff, ORDER GRANTING DEFENDANT LYFT, INC.’S MOTION 13 vs. FOR EXTENSION OF TIME TO RESPOND TO: 14 LYFT, INC., a Delaware Company; et al., (1) PLAINTIFF’S RESPONSE TO 15 Defendants. DEFENDANT’S MOTION TO 16 STRIKE [ECF NO. 103] [ECF NO. 106]; 17 (2) PLAINTIFF’S RESPONSE TO 18 DEFENDANT’S ATTORNEY MOTION FOR SANCTIONS [ECF 19 NO. 105] [ECF NO. 109]; AND 20 (3) PLAINTIFF’S MOTION TO STAY 21 INTERLOCUTORY ORDER ECF NO. 81 COMPELLING PLAINTIFF 22 TO ARBITRATION UNTIL DECISION FROM CHIEF JUDGE 23 ANDREW P. GORDON HAS BEEN GIVEN [ECF NO. 108] 24 25 (FIRST REQUEST) Defendant Lyft, Inc. (“Defendant”), by and through its counsel, Jackson Lewis P.C., hereby 26 submits the instant Motion for Extension of Time to Respond to Plaintiff’s Responses to 27 1 Stay Interlocutory Order ECF No. 81 Compelling Plaintiff to Arbitration Until Decision from Chief 2 Judge Andrew P. Gordon Has Been Given (collectively the “Motion”). This Motion is based on the 3 following Memorandum of Points and Authorities, all pleadings and documents on file with the 4 Court, and any oral argument that the Court deems proper. 5 MEMORANDUM OF POINTS AND AUTHORITIES 6 I. BACKGROUND 7 This matter is currently stayed pending completion of arbitration. See ECF Nos. 81 and 95. 8 Nevertheless, Plaintiff Rafford Broadnax (“Plaintiff”) continues to file motions flouting the stay 9 order. Plaintiff has engaged in appalling behavior toward Defendant and members of this Court, 10 filing motions for sanctions, motions to disqualify judges, and motions to amend the caption of 11 pleadings, at the cost of time and resources of this Court and Defendant. Shortly after this Court 12 issued its Order (1) Denying Motion to Vacate Order and (2) Denying Other Motions [ECF No. 95] 13 on November 13, 2025, which reinforced the stay pending completion of arbitration, Plaintiff 14 continues to file motions and other filings before this Court, which includes Plaintiff’s instant 15 Motion to Stay the Order Compelling Arbitration. Defendant’s Replies in Support of its Motion to 16 Strike and for Sanctions are due this Friday, December 19, 2025, and the Response to Plaintiff’s 17 latest motion is due on December 26, 2025. 18 Defendant now seeks an extension to prepare an appropriate response to Plaintiff’s filings. 19 There are multiple reasons for this request. One is due to the upcoming Christmas and New Year 20 holidays, which make it difficult to facilitate communications with counsel regarding any draft 21 revisions of motions. Given the current stay order in place, Defendant wants to be careful about the 22 filings placed before this Court, which may require additional consultation prior to submission. 23 Additionally, for judicial economy, Defendant also believes the replies and the response should be 24 submitted at the same time. Defendant believes that all of these ends can be achieved with an 25 extension to file to Friday, January 9, 2026. 26 II. LEGAL ARGUMENT 27 FRCP 6(b)(1) provides that when an act must be done within a specified time, the Court 1 request is made, before the original time or its extension expires . . . .” “Good cause” is not a 2 rigorous or high standard, and courts have construed the test broadly. Ahanchion v. Kenan Pictures, 3 624 F.3d 1253 (9th Cir. 2010). Rule 6(b) “[is] to be liberally construed to effectuate the general 4 purpose of seeing that cases are tried on the merits.” Rodgers v. Watt, 722 F.2d 456, 459 (9th Cir. 5 1983); Wong v. Regents of the Univ. of Calif., 410 F.3d 1052, 1060 (9th Cir. 2005) (“Of course, 6 courts should not mindlessly enforce deadlines.”). Indeed, the “good cause” standard “primarily 7 considers the diligence of the party seeking the amendment.” In re W. States Wholesale Nat. Gas 8 Antitrust Litig., 715 F.3d 716, 737 (9th Cir. 2013). 9 In general, an application for extension of time under Rule 6(b)(1)(A) will be granted in the 10 absence of bad faith. Ahanchion, 624 F.3d at 1259 (quoting 4B CHARLES ALAN WRIGHT & ARTHUR 11 R. MILLER, FEDERAL PRACTICE AND PROCEDURE § 1165 (3d ed. 2004)) (internal quotations 12 omitted). 13 Here, Defendant believes its request is reasonable and that good cause exists to extend the 14 deadline for Defendant to respond to ECF Nos. 106, 108, and 109, due to both the intervening 15 Christmas and New Year holidays, extra consideration given the stay order in place, and judicial 16 economy. See Lomax v. Hutchings, No. 2:23-cv-01284-CDS-EJY, 2025 U.S. Dist. LEXIS 111282, 17 at *1 (D. Nev. June 6, 2025) (granting defendants’ motion to extend deadline to file their motion 18 for summary judgment where defendants’ counsel had obligations in other matters that prevented 19 him from meeting the dispositive motion deadline); Michaud v. Baker, No. 3:17-cv-00718-MMD- 20 CBC, 2019 U.S. Dist. LEXIS 53069, at *2 (D. Nev. Mar. 19, 2019) (citing Canup v. Miss. Valley 21 Barge Line Co., 31 F.R.D. 282, 283 (D. Pa. 1962) (explaining that the “practicalities of life” (such 22 as an attorney’s “conflicting professional engagements” or personal commitments such as 23 vacations, family activities, illnesses, or death) often necessitate an enlargement of time to comply 24 with a court deadline). Defendant makes such requests in good faith and not for the purpose of 25 delay. 26 Defendant wants to ensure that all information is utilized and encapsulated in its response(s) 27 prior to filing. Moreover, Defendant brings the instant motion before the deadline to respond has 1 || 624 F.3d 1253, 1259 (9th Cir. 2010) (requests for extensions of time made before the applicabl 2 || deadline has passed should generally be granted in the absence of bad faith or prejudice to advers 3 || party). 4 Considering the circumstances detailed above, Defendant submits that its request for a 5 ||extension up to and including January 9, 2026 is reasonable. This is the first request fron 6 || Defendant for an extension of time to respond to ECF 106, 108, and 109, and Defendant make 7 || such request in good faith and not for the purpose of delay. 8 Accordingly, good cause exists to grant Defendant’s Motion and allow Defendant up to an 9 || including January 9, 2026 to respond to ECF Nos. 106, 108, and 109. 10 Dated this 18 day of December, 2025. JACKSON LEWIS P.C. 11 /s/ Amanda Patanaphan 12 Amanda Patanaphan, Bar No. 15080 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 14 Attorneys for Defendant 15 16 IT |S SO ORDERED: 17 Dated:_December 19, 2025

19 ANDREW P. GORDON 20 CHIEF UNITED STATES DISTRICT JUDGE 21 22 23 24 25 26 27 28