Kleip-Sotelo v. Absolute Dental & Orthodontics Prada, PLLC, a Domestic Professional Limited Liability Company, Does I-X Roe Corporations I-X

1 WENDY M. KRINCEK, ESQ., Bar #6417 AMY THOMPSON, ESQ., Bar #11907 LITTLER MENDELSON, P.C.

3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89169-5937 Telephone: 702.862.8800 Fax No.: 702.862.8811 Email: [email protected] [email protected] Attorneys for Defendant ABSOLUTE DENTAL & ORTHODONTICS PRADA, PLLC.

9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA PAULINA KLEIP-SOTELO, an Individual, 12 Plaintiff, Case No. 2:20-cv-00021-KJD-DJA vs. ABSOLUTE DENTAL & ORTHODONTICS PRADA, PLLC., a STIPULATION FOR EXTENSION OF TIME Domestic Professional Limited Liability TO RESPOND TO COMPLAINT Company, DOES I -X; ROE CORPORATIONS I -X., (FIRST REQUEST) Defendant.

18 Pursuant to LR IA 6-1 and LR 7-1, Plaintiff, PAULINA KLEIP-SOTELO, and Defendant ABSOLUTE DENTAL & ORTHODONTICS PRADA, PLLC., through their respective attorneys of record, hereby stipulate and agree that Defendant has until April 30, 2020 to respond to the Complaint.

21 Defendant was served with a copy of the Summons and Complaint on January 9, 2020. However, Defendant did not receive notice that it had been served until April 9, 2020.1 Good cause exists to grant this extension because Defendant requires time to investigate and prepare its response to the Complaint. If the requested extension is granted, Defendant will file its response on or before April 1 Defendant certainly intends to defend itself in this case and the lack of notice of service is sufficient grounds to warrant additional time to respond to the complaint pursuant to LR IA 6-1(a). See e.g., Las Vegas Sands Corp. v. First Cagayan Leisure & Resort Corp., No. 214CV424JCMNJK, 2016 WL 447481, at *2 (D.

Nev. Feb. 3, 2016).

30, 2020. This is the first request for an extension made by the parties and the parties make this request in good faith and not for the purpose of delay.

4 IT IS SO STIPULATED. > Dated: April 13, 2020 Dated: April 13, 2020 Respectfully submitted, Respectfully submitted, g | Jenny L. Foley /s/_ Amy L. Thompson JENNY L. FOLEY, PH.D., ESQ. WENDY M. KRINCEK, ESQ.

9 | MARTA D. KURSHUMOVA, ESQ. AMY L. THOMPSON, ESQ.

HKM EMPLOYMENT ATTORNEYS LLP — LITTLER MENDELSON, P.C.

Attorney for Plaintiff Attorneys for Defendant 11 : L ABSOLUTE DENTAL & ORTHODONTICS PAULINA KLEIP-SOTELO PRADA, PLLC.

14 IT IS SO ORDERED.

15 DATED: April 14, 2020 16 | \ A ) 17 THE HONORABLE U.S. MAGISTRATE 8 JUDGE DANIEL J. ALBREGTS |) 4gio-7519-7881.1 051901.1013 2.