Haro, III v. Thomas Keller Restaurant Group

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 DIONE C. WRENN, ESQ.

Nevada Bar No. 13285 GORDON REES SCULLY MANSUKHANI, LLP 300 South 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Facsimile: (702) 255-2858 E-Mail: [email protected] 7 [email protected] Attorneys for Defendants, KRM, Inc, d.b.a Thomas Keller Restaurant Group and KVP, LP d.b.a. Bouchon Restaurant UNITED STATES DISTRICT COURT DISTRICT OF NEVADA FERNANDO HARO III, an individual, ) CASE NO.: 2:20-cv-02113-APG-DJA 13 ) Plaintiff, ) 14 ) STIPULATION AND ORDER TO vs. ) EXTEND TIME TO FILE 15 ) REPLIES IN SUPPORT OF KRM, INC. d.b.a. “THOMAS KELLER DEFENDANTS KRM, INC. AND ) R anE dS KT VA PU ,R LA PN dT .b .G a.R “O BU OP U” C, a H f Oo Nre i Agn T c To Hrp Eo ration; ) KVP, LP’S T OSP DE IC SI MA IL S SM OTIONS VENETIAN,” a foreign Limited Liability ) Company, ) (First Request) 18 ) Defendants. ) 19 ) 20 Pursuant to Local Rule IA 7-1, Defendants KRM, Inc, d.b.a Thomas Keller Restaurant Group (“KRM”) and KVP, LP d.b.a. Bouchon Restaurant (erroneously named as TK Las Vegas, LLC d.b.a “Bouchon at the Venetian”) (“KVP”) (collectively, “Defendants”), by and through their attorneys, Robert S. Larsen, Esq. and Dione C. Wrenn, Esq. of the law firm of Gordon Rees Scully Mansukhani LLP, and Plaintiff Fernando Haro III, in proper person, hereby stipulate and agree as follows: 26 1. Plaintiff filed his Complaint on November 16, 2020.

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

1 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.

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

6 6. On July 2, 2021, Defendants filed their respective Special Motions to Dismiss Plaintiff’s Second Amended Complaint (“Motions”). ECF Nos. 26 & 27.

8 7. Plaintiff’s initial deadline to respond to Defendants’ Motions was July 19, 2021.

9 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, 2021, this Court granted the stipulation. ECF No. 31.

12 9. On August 25, 2021, the parties filed a joint stipulation to extend Plaintiff’s deadline to file responses to Defendants’ Motions to September 17, 2021. ECF No. 32. On August 26, 2021, the Court granted the second request for an extension. ECF No. 33.

15 10. The deadline for Defendants’ to file replies in support of their respective Motions was September 27, 2021.

17 11. Due to illness, defense counsel was unable to file on September 27, 2021.

18 12. Counsel for Defendants requests a one (1) week extension to October 4, 2021 to file the replies.

20 13. There are currently no scheduled hearings in this case. Defendants’ sought extension will not unduly delay the proceedings.

22 14. Plaintiff does not oppose an extension up to and including October 4, 2021.

23 15. Accordingly, Defendants’ shall have until October 4, 2021, to file the replies in support of Defendants’ Motions.

25 / / / / / / / / / 1 16. This stipulation is not made for purposes of delay.

2 IT IS SO STIPULATED.

3 || DATED this 28th day of September 2021. DATED this 28th day of September 2021. + || GORDON REES SCULLY FERNANDO HARO III MANSUKHANI || 4/ Dione C. Wrenn /s/ Fernando Haro ROBERT S. LARSEN, ESQ. FERNANDO HARO II Nevada Bar No. 7785 PO. Box any 89180 DIONE C. WRENN, ESQ. as vegas, g , Nevada Bar No. 13285 Plaintiff In Proper Person || 300 South 4" Street, Suite 1550 Las Vegas, Nevada 89101 || Attorneys for Defendants IT IS SO ORDERED.

Wy 13 fe 3 UNITED STATES DISTRICT COURT JUDGE DATED: _ September 28, 2021 Bm 15

Sm $$