Haro, III v. Thomas Keller Restaurant Group

1 |] FERNANDO HARO HUI P.O. BOX 81972 LAS VEGAS, NV 89180 ||(702) 918-1910 [email protected] PROPER PERSON 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA || FERNANDO HARO III, an individual; CASE NO.: 2:20-cv-02113-APG-DJA Plaintiff, Vs STIPULATION AND ORDER TO INC. dba. “THOMAS KELLER EXTEND TIME TO FILE OPPOSITION |} RESTAURANT GROUP”, a foreign TO MOTIONS TO DISMISS corporation; and KVP, LP d.b.a. “BOUCHON !3 || AT THE VENETIAN,” a foreign Limited || Liability Company; 15 Defendants.

17 Pro se Plaintiff Fernando Haro II (“Plaintiff”) and Defendants KRM, Inc, d.b.a. Thomas 18 Keller Restaurant Group and KVP, LP d.b.a. Bouchon Restaurant (collectively, “Defendants”), by and through their attorneys, hereby stipulate and agree as follows: 1. Plaintiff filed his Complaint on November 16, 2020.

2. Plaintiff filed his First Amended Complaint on February 21, 2021.

23 3. Pursuant to Court Order [ECF No. 17], Defendants deadline to file their responses 24 Plaintiffs First Amended Complaint was June 21, 2021.

25 4. On June 21, 2021, the parties filed a stipulation to extend Defendants deadline to file their responses to July 2, 2021, which the Court granted. ECF Nos. 18 & 19.

38 5. On June 30, 2021, Plaintiff filed a Second Amended Complaint. ECF No. 22.

STIPULATION AND PROPOSED ORDER TO EXTEND TIME 1 1 6. On July 2, 2021, Defendants filed their respective Special Motions to Dismiss ? || Plaintiff's Second Amended Complaint (“Motions”). ECF Nos. 26 & 27.

7. Plaintiff's deadline to respond to Defendants’ Motions is July 19, 2021.

5 8. Plaintiff avers that he needs additional time to locate, organize, and review ||relevant documents and prepare the appropriate responses. Plaintiff requests additional time to 7 his two responses up to and including August 27, 2021.

8 9. There are currently no scheduled hearings in this case. Plaintiffs sought extension will not unduly delay the proceedings.

10. Defendants do not oppose Plaintiff's requested extension.

12 11. Accordingly, Plaintiff shall have until August 27, 2021, to file responses to || Defendants Motions.

14 12. This stipulation is not made for purposes of delay.

IT IS SO STIPULATED.

17 || DATED this 16" day of July 2021 DATED this 16" day of July 2021 1g || GORDON REES SCULLY FERNANDO HARO III MANSUKHANI ||/s/ Dione C. Wrenn /s/ Fernando Haro |) DIONE C. WRENN, ESQ. FERNANDO HARO III Nevada Bar No. 13285 P.O. Box 81972 300 South 4" Street, Suite 1550 Las Vegas, NV 89180 || Las Vegas, Nevada 89101 Plaintiff in Proper Person Attorneys for Defendants °5 IT IS SO ORDERED.

26 CZ July 23, 2021 27 UNITED STATES DISTRICT JUDGE DATED STIPULATION AND PROPOSED ORDER TO EXTEND TIME 2