Haro, III v. Thomas Keller Restaurant Group

1 FERNANDO HARO III P.O. BOX 81972 LAS VEGAS, NV 89180 (702) 918-1910 [email protected] PROPER PERSON UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA FERNANDO HARO III, an individual; CASE NO.: 2:20-cv-02113-APG-DJA 9 Plaintiff, vs. STIPULATION AND ORDER TO KRM, INC. d.b.a. “THOMAS KELLER EXTEND TIME TO FILE OPPOSITION RESTAURANT GROUP”, a foreign TO MOTIONS TO DISMISS corporation; and KVP, LP d.b.a. “BOUCHON AT THE VENETIAN,” a foreign Limited SECOND REQUEST Liability Company; 15 Defendants.

17 Pro se Plaintiff Fernando Haro III (“Plaintiff”) and Defendants KRM, Inc, d.b.a. Thomas 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], Defendant’s deadline to file their responses to Plaintiff’s First Amended Complaint was June 21, 2021.

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

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 initial deadline to respond to Defendants’ Motions was July 19, 2021.

5 8. On July 19, 2021, the parties jointly submitted a stipulation to extend Plaintiff's || deadline to file responses to Defendants’ Motions to August 27, 2021. ECF No. 30. On July 23, 7 this Court granted the stipulation. ECF No. 31.

8 9. Plaintiff avers that he needs additional time to locate, organize, and review relevant documents and prepare the appropriate responses.

10. There are currently no scheduled hearings in this case. Plaintiff's sought extension || will not unduly delay the proceedings.

13 11. Defendants do not oppose an extension up to and including September 17, 2021.

12. Accordingly, Plaintiff shall have until September 17, 2021, to file responses to Defendants’ Motions.

IT IS SO STIPULATED.

1g || DATED this 23rd day of August 2021 DATED this 23rd day of August 2021 ||} 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 > IT ISSO ORDERED. ( So 8/26/2021 27 ANDREW P. GORDON DATED 38 UNITED STATES DISTRICT JUDGE STIPULATION AND PROPOSED ORDER TO EXTEND TIME 2