Wood v. Carl's Jr.

Opinion

1 ROBERT S. LARSEN, ESQ. Nevada Bar No. 7785 2 RACHEL L. WISE, ESQ. Nevada Bar No. 12303 3 GORDON REES SCULLY MANSUKHANI, LLP 300 So. 4th Street, Suite 1550 4 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 5 Facsimile: (702) 255-2858 E-Mail: rlarsen@grsm.com 6 rwise@grsm.com

7 Attorneys for S.L. Investments

8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 HOLLY MARIE WOOD, an individual, Case No.: 2:20-cv-02329-APG-BNW 11 Plaintiff, 12 vs. STIPULATION AND ORDER TO 13 EXTEND TIME TO FILE REPLY IN CARL’S JR., operated and owned by BTO SUPPORT OF S.L. INVESTMENT’S 14 INVESTMENTS, a Delaware corporation; S. L. MOTION FOR SANCTIONS INVESTMENTS, a Nevada corporation; CKE 15 RESTAURANTS, INC., a Delaware corporation; (FIRST REQUEST) CARL’S J. RESTAURANTS, LLC, a foreign limited 16 liability company; CARL KARCHER ENERPRISES, INC. a foreign corporation; CKE 17 RESTAURANTS HOLDINGS, INC., a foreign corporation; RUCEY MOLINA CRUZ, an 18 individual; DOES 1 through 10, inclusive; ROE CORPORATIONS/ENTITIES 1 through 10, 19 inclusive,

20 Defendants.

22 In accordance with Local Rules 6-1 and 7-1, Plaintiff Holly Marie Wood and Defendant 23 S.L. Investments, Inc. by and through their respective attorneys of record, stipulate as follows: 24 1. On August 3, 2021, Defendant S.L. Investments, Inc. filed the Motion for 25 Sanctions [ECF No. 50]. 26 2. Plaintiff filed her Opposition to Defendant S.L. Investments, Inc.’s Motion for 27 FRCP 11 Sanctions on October 25, 2021 [ECF No. 61]. 1 in support of the Motion for Sanctions on or before November 8, 2021. 2 In Support of this Stipulation, the Parties agree to the following: 3 1. Good cause exists to support this request for additional time. Defendant’s counsel 4 has been diligently working on a reply to the pending opposition, but due to recent circumstances 5 will not be able to timely complete a response. Due to time commitments involving other cases 6 and a medical matter, Defendant’s counsel has not been able to dedicate the time necessary for 7 completing and filing an appropriate reply. Due to an outpatient procedure on October 27, 2021, 8 Defendant’s counsel was unable to perform sufficient work on any of her cases, including this 9 one. Additionally, during the past week, Defendant’s counsel has worked on propounding 10 discovery, drafting objections and cross-examination to multiple depositions by written question, 11 preparing for upcoming depositions, and performing due diligence relevant to opinion matters. 12 2. An additional week will provide the undersigned counsel sufficient time to 13 finalize and file a reply to the pending opposition. 14 3. The undersigned counsel conferred with Plaintiffs’ counsel and Plaintiffs do not 15 oppose the extension request. 16 4. This stipulation is not made for purposes of delay. 17 / / / 18 / / / 19 / / / 20

21 22 23 24 25 26 27 1 5. Therefore, the parties agree that S.L. Investments, Inc.’s Reply in support of the 2 || Motions to Sanction is now due on or before November 8, 2021. 3 The Parties respectfully request that the court approve this Stipulation. DATED this 29" day of October, 2021. DATED this 29" day of October, 2021. PAUL PADDA LAW PLLC GORDON REES SCULLY 6 MANSUKHANI, LLP 7 |\/s/ Paul S. Padda /s/ Rachel L. Wise Paul S. Padda, Esq. Robert S. Larsen, Esq. 8 || Tony L. Abbatangelo, Esq. Nevada Bar No. 7785 4030 S. Jones Blvd., Unit 30370 Rachel L. Wise, Esq. 9 || Las Vegas, NV 89173 Nevada Bar No. 12303 psp @ paulpaddalaw.com 300 So. 4" Street, Suite 1550 10 || tony@paulpaddalaw.com Las Vegas, Nevada 89101

3 11 || Attorneys for Plaintiff Attorneys for S.L. Investments

Bh az IT IS SO ORDERED \4 9 a = ~ gag 15 Lf

ge” 16 UNITED STATES DISTRICT JUDGE

fo 17 18 DATED: November 2, 2021 19 20 21 22 23 24 25 26 27 28