Wood v. Carl's Jr.

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 RACHEL L. WISE, ESQ.

Nevada Bar No. 12303 GORDON REES SCULLY MANSUKHANI, LLP So. 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Facsimile: (702) 255-2858 E-Mail: [email protected] 6 [email protected] Attorneys for S.L. Investments UNITED STATES DISTRICT COURT DISTRICT OF NEVADA HOLLY MARIE WOOD, an individual, Case No.: 2:20-cv-02329-APG-BNW Plaintiff, vs. STIPULATION AND ORDER TO 13 EXTEND TIME TO FILE REPLY IN CARL’S JR., operated and owned by BTO SUPPORT OF S.L. INVESTMENT’S INVESTMENTS, a Delaware corporation; S. L. MOTION FOR SANCTIONS INVESTMENTS, a Nevada corporation; CKE RESTAURANTS, INC., a Delaware corporation; (FIRST REQUEST) CARL’S J. RESTAURANTS, LLC, a foreign limited liability company; CARL KARCHER ENERPRISES, INC. a foreign corporation; CKE RESTAURANTS HOLDINGS, INC., a foreign corporation; RUCEY MOLINA CRUZ, an individual; DOES 1 through 10, inclusive; ROE CORPORATIONS/ENTITIES 1 through 10, inclusive, 20 Defendants.

22 In accordance with Local Rules 6-1 and 7-1, Plaintiff Holly Marie Wood and Defendant S.L. Investments, Inc. by and through their respective attorneys of record, stipulate as follows: 24 1. On August 3, 2021, Defendant S.L. Investments, Inc. filed the Motion for Sanctions [ECF No. 50].

26 2. Plaintiff filed her Opposition to Defendant S.L. Investments, Inc.’s Motion for FRCP 11 Sanctions on October 25, 2021 [ECF No. 61].

1 in support of the Motion for Sanctions on or before November 8, 2021.

2 In Support of this Stipulation, the Parties agree to the following: 3 1. Good cause exists to support this request for additional time. Defendant’s counsel has been diligently working on a reply to the pending opposition, but due to recent circumstances will not be able to timely complete a response. Due to time commitments involving other cases and a medical matter, Defendant’s counsel has not been able to dedicate the time necessary for completing and filing an appropriate reply. Due to an outpatient procedure on October 27, 2021, Defendant’s counsel was unable to perform sufficient work on any of her cases, including this one. Additionally, during the past week, Defendant’s counsel has worked on propounding discovery, drafting objections and cross-examination to multiple depositions by written question, preparing for upcoming depositions, and performing due diligence relevant to opinion matters.

12 2. An additional week will provide the undersigned counsel sufficient time to finalize and file a reply to the pending opposition.

14 3. The undersigned counsel conferred with Plaintiffs’ counsel and Plaintiffs do not oppose the extension request.

16 4. This stipulation is not made for purposes of delay.

17 / / / / / / / / / 1 5. Therefore, the parties agree that S.L. Investments, Inc.’s Reply in support of the || Motions to Sanction is now due on or before November 8, 2021.

3 The Parties respectfully request that the court approve this Stipulation.

DATED this 29" day of October, 2021. DATED this 29" day of October, 2021.

PAUL PADDA LAW PLLC GORDON REES SCULLY 6 MANSUKHANI, LLP |\/s/ Paul S. Padda /s/ Rachel L. Wise Paul S. Padda, Esq. Robert S. Larsen, Esq.

8 || Tony L. Abbatangelo, Esq. Nevada Bar No. 7785 4030 S. Jones Blvd., Unit 30370 Rachel L. Wise, Esq.

9 || Las Vegas, NV 89173 Nevada Bar No. 12303 psp @ paulpaddalaw.com 300 So. 4" Street, Suite 1550 || [email protected] Las Vegas, Nevada 89101 3 11 || Attorneys for Plaintiff Attorneys for S.L. Investments

Bh az IT IS SO ORDERED \4 a = ~ gag 15 Lf ge” 16 UNITED STATES DISTRICT JUDGE fo 18 DATED: November 2, 2021