Rahimian v. Adriano

Opinion

JAMES P. KEMP, ESQUIRE Nevada Bar No. 006375 KEMP & KEMP, ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 (702) 258-1183 / (702) 258-6983 (fax) jp@kemp-attorneys.com Attorney for Plaintiff and all others similarly situated

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA SHAHROOZ RAHIMIAN, individually Case No. 2:20-cv-02189-ART-VCF and on behalf of all others similarly ORDER APPROVING situated, STIPULATION AND PROPOSED Plaintiff. ORDER FOR EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO y. DEFENDANTS’ MOTION TO DISMISS RACHEL ADRIANO, and JUAN First R t MARTINEZ, INC., (First Request) Defendants. Plaintiff Shahrooz Rahimian and Defendants Rachel Adriano and Juan Martinez, Inc. d/b/a Century 21 Americana hereby stipulate, agree, and move the Court to extend the deadline for Plaintiff to respond to Defendants’ motion to dismiss for good cause, in support thereof states as follows: 1. On April 6, 2022, Plaintiff filed a Second Amended Complaint in this action. 2. Defendants Rachel Adriano and Century 21 Americana’s motion to dismiss the second amended complaint was filed on April 20, 2022 (ECF No. 32). Accordingly, Plaintiff's response is due on May 4, 2022. 3. Plaintiff and Defendants agree that Plaintiff shall have a two week extension of time up to and including May 18, 2022 to file a response to the motion to dismiss. The parties

also agree to a one week extension of time for Defendants to file their reply, up to and including June 1, 2022. This is the first request for an extension of time to respond and reply to the motion. 4. The extension is requested to permit the Plaintiff and counsel sufficient time to review and appropriately respond to the opposing party’s arguments. 5. The stipulated extension will not prejudice the parties, nor will it impact other deadlines in this case. SO STIPULATED.

Respectfully submitted, Dated: May 4, 2022. /s/ Avi R. Kaufman Avi R. Kaufman (Florida Bar no. 84382) KAUFMAN P.A. 400 NW 26" Street Miami, Florida 33127 Telephone: (305) 469-5881 Email: kaufman@kaufmanpa.com JAMES P. KEMP, ESQUIRE Nevada Bar No. 006375 KEMP & KEMP, ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 (702) 258-1183 / (702) 258-6983 (fax) ip@kemp-attorneys.com Counsel for Plaintiff and all others similarly situated

KAEMPFER CROWELL Dated: May 4, 2022. /s/ Robert McCo Robert McCoy, No. 9121 Ryan M. Lower, No. 9108 Briana Martinez, No. 14919 1980 Festival Plaza Drive, Suite 650 Las Vegas, Nevada 89135 Telephone: (702) 792-7000 Facsimile: (702) 796-7181

Email: rmccoy@kenvlaw.com Email: rlower@kcnvlaw.com Email: bmartinez@kcnvlaw.com Attorneys for Defendants

IT IS SO ORDERED. R. Traum UNITED STATES DISTRICT JUDGE DATED: May 5, 2022