Rose Tiffany Evans v. Defendant

Opinion

DISTRICT OF NEVADA Rose Tiffany Evans, Case No. 2:25-cv-00084-JAD-NJK Order Granting Plaintiff, Defendant’s Motion For Two Day Extension to File Opposition to Vv. Plaintiff's Motion to Compel a ot IS Defendant. (First Request) Defendant hereby submits this motion for 2-day extension to file its opposition to Plaintiff's Motion to Compel. ECF No. 57. This is the first, and last, request for the extension. Introduction Plaintiff filed a motion to compel on July 7, 2026. ECF No. 57. The court shortened the deadline for Defendant to submit its response to July 9, 2026, and required 94 that any reply by Plaintiff be due by July 13, 2026. ECF No. 59. Defendant is requesting a two-day extension for its opposition due to Defendant’s counsel being out of the Jurisdiction with limited ability to provide a full response to the motion. Defendant is aware that the two-day request would mean that the response deadline would be due on 2g ||Saturday, July 11, 2026, but due to the nature of this motion and the desire of the court to

address the motion on an expeditated basis, is willing to work to get it done outside of usual business days. I. Law and Argument FRCP 6(b) addresses extending time, stating: (1) In General. When an act may or must be done within a specified time, the court may, for good cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires; or (B) on motion made after the time has expired if the party failed to act because of excusable neglect. The proper procedure, when additional time for any purpose is needed, is to present the request for extension of time before time then fixed for purpose in question has expired. Canup v. Mississippi Val. Barge Line Co., 31 F.R.D. 282 (W.D.Pa.1962). Extensions of time may always be asked for, and usually are granted on a showing of good cause if timely made under subdivision (b)(1) of the Rule. Creedon v. Taubman, 8 F.R.D. 268 (N.D.Ohio 1947). Good cause exists to enlarge the time by which a party may file a brief where additional time is needed to prepare such a brief. See O'Connor v. U.S. LR.S., 698 F.Supp. 204, 205 (D. Nev. 1988) (district court granted plaintiffs' motion for an extension of time to oppose a motion for summary judgment); Germaine Music v. Universal Songs of Polygram, 275 F.Supp.2d 1288, 1301 (district court granted movant's motion for additional time to oppose a motion for summary judgment, in part due to movant's need to acquire or prepare extensive documents so as to be able to adequately oppose the motion). Counsel for Defendant is at a training conference in Portland, Oregon from July 7, 2026 until Friday, July 10, 2026. At this conference he has access to his emails, but has a limited ability to access documents and filings. Counsel is scheduled to arrive back in Las Vegas at 12:35pm on July 10, 2026. Counsel plans to immediately begin work on the response to the motion to compel upon his arrival back into Las Vegas on July 10, 2026. Counsel seeks a two-day extension of the Court’s deadline just to ensure that if there is a travel delay or other concern that arises that causes a delay on the arrival. Counsel is aware that the two-day request would

mean that the response deadline would be due on Saturday, July 11, 2026, but due to the nature of this motion and the desire of the court to address the motion on an expeditated basis, Counsel is willing to work to get it done outside of usual business days if an issue arises resulting in the travel delay. Counsel is going to do his best to ensure the response is filed before end of the day on July 10, 2026. Counsel has no opposition if this court also enlarges the time for Plaintiff to file her reply based upon counsel’s request. Conclusion Based on the reasons and circumstances above, Defendant respectfully requests that the Court grant this motion to extend the deadline for the response to the motion to compel to Saturday, July 11, 2026. Respectfully submitted this 8th day of July 2026. Acting Attorney General of the United States First Assistant United States Attorney Ls/ Nathan M. Claus Assistant United States Attorney Defendant's response to the motion to compel is due no later than July 13, 2026. Any reply must be filed no later than July 20, 2026.

IS SO ORDERED Dated: July 9, 2026 ] . wf : Nancy J. Koppe United States Magistrate Judge