Nguyen v. Smith Salon, LLC

1 AMANDA L. IRELAND, ESQ.

Nevada Bar No. 13155 IRELAND LAW GROUP, LLC 7854 West Sahara Ave. Las Vegas, Nevada 89117 T: (702) 427-2110 F: (702) 441-7637 E: [email protected] and GABRIEL L. GRASSO, ESQ.

6 Nevada Bar No. 7358 GABRIEL L. GRASSO, P.C.

7 411 South 6th Street Las Vegas, NV 89101 T: (702) 868-8866 F: (702) 868-5778 E: [email protected] Attorneys for Defendants UNITED STATES DISTRICT COURT DISTRICT OF NEVADA SARA KIM NGUYEN, individually, Case No.: 2:21-cv-00213-KJD-BNW Plaintiff, 14 STIPULATION AND PROPOSED vs. ORDER TO EXTEND TIME FOR 15 PLAINTIFF TO RESPOND TO LANE F. SMITH, M.D., individually; SMITH DEFENDANT’S PENDING MOTIONS SALON, LLC dba Chic La Vie, a Limited- TO SEAL OR STRIKE Liability Company; SMITH PLASTIC AND SURGERY INSTITUTE, PC, a Professional TO EXTEND TIME FOR Corporation; SMITH PLASTIC SURGERY CORPORATE DEFENDANTS TO BUILDING LLC, a Limited-Liability Company; RESPOND TO THE COMPLAINT ROE ENTITIES I – V, inclusive, (First Request) Defendants.

Defendant Lane F. Smith, M.D. (hereinafter “Dr. Smith”) by and through his counsel, Amanda L. Ireland, Esq. and Gabriel L. Grasso, Esq., and Plaintiff, Sarah Kim Nguyen, (hereinafter “Plaintiff”) by and through her counsel of record Andre M. Lagomarsino, Esq. and Cory M. Ford, Esq., do hereby stipulate and agree to an 11-day extension of time for Plaintiff to respond to Defendant’s Motion to Seal Complaint, or, in the Alternative, Motion to Strike Scandalous Immaterial Matter (Doc. #9)(“Motion to Seal or Strike”) from March 12, 2021 until March 22, 2021. The Complaint was filed on February 9, 2021, and the Motion to Seal or Strike was filed on February 26, 2021.

The parties further stipulate and agree to extend the time for the corporate defendants (Smith Salon, LLC, Smith Plastic Surgery Institute, PC, and Smith Plastic Surgery Building, LLC) to appear and respond to the Plaintiff’s Complaint (Doc. #1) from March 15, 2021 until 14 days after notice of the Court’s action on the Motion to Seal or Strike.

These requests are submitted pursuant to Local Rules IA 6-1, 6-2 and II 7-1 and the Federal Rules of Civil Procedure 12(a)(4), and 12(f), and are the parties’ first requests for an extension of pending deadlines.

11 These extensions are requested due to agreements between counsel for the parties, and for good cause. Counsel for Dr. Smith sought an extension for the corporate defendants to respond to the Complaint in the interests of litigation efficiency and avoiding needless duplication of responsive pleadings in light of Dr. Smith’s FRCP 12(b) Motion to Seal or Strike.

Meanwhile, counsel for the Plaintiff requested an extension to respond to the Motion to Seal or Strike due to an attorney leaving his law office to start his own practice.

16 Accordingly, Plaintiff shall have up to and including March 22, 2021 to respond to Defendant’s Motion to Seal or Strike, and the corporate defendants (Smith Salon, LLC, Smith Plastic Surgery Institute, PC, and Smith Plastic Surgery Building, LLC) shall have until 14 days after notice of the Court’s action on the Motion to Seal or Strike.

1 || Dated this 11" day of March 2021. Dated this 11" day of March 2021.

2 || IRELAND LAW GROUP, LLC LAGOMARSINO LAW 3 /s/ Amanda L. Ireland /s/ Andre M. Lagomarsino eee By: eee || AMANDA L. IRELAND, ESQ. ANDRE M. LAGOMARSINO, ESQ.

7854 West Sahara Ave. CORY M. FORD, ESQ.

5 || Las Vegas, Nevada 89117 3005 W. Horizon Ridge Pkwy. #241 Tel: (702) 427-2110 Henderson, Nevada 89052 || Fax: (702) 441-7637 [email protected] [email protected] [email protected] || GABRIEL L. GRASSO, ESQ. Phone: (702) 383-2864 GABRIEL L. GRASSO, P.C. Fax: (702) 383-0065 || Nevada Bar No. 7358 411 South 6" Street Attorneys for Plaintiff || Las Vegas, NV 89101 || Attorneys for Defendants 16 IT ISSO ORDERED: 17 Gu ls 18 UNITED STATES DISTRICT JUDGE 19 Dated: March 15 _, 2021