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 REPLY IN RESTAURANT GROUP”, a foreign SUPPORT OF PLAINTIFF’S MOTION corporation; and KVP, LP d.b.a. “BOUCHON TO ALLOW TIME FOR DISCOVERY AT THE VENETIAN,” a foreign Limited Liability Company; (First Request) 15 Defendants.

16 Pursuant to Local Rule IA 7-1, Plaintiff Fernando Haro III, in proper person, and Defendants KRM, Inc, d.b.a Thomas Keller Restaurant Group (“KRM”) and KVP, LP d.b.a.

Bouchon at the Venetian (“Bouchon”) (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, hereby stipulate and agree as follows: 1. On October 14, 2021, Plaintiff filed a Motion to Allow Time For Discovery Pursuant to Rule 56(d). ECF No. 43.

25 2. On October 28, 2021, Defendants filed their response in Opposition to Plaintiff’s Motion to Allow Time for Discovery Pursuant to Rule 56(d). ECF No. 44.

28 1 1 3. The deadline for Plaintiff to file a reply in support of his Motion to Allow Time Discovery was November 4, 2021.

4. Due to illness, Plaintiff was unable to file his reply on November 4, 2021.

5 5. Plaintiff requests a one (1) week extension to November 11, 2021 to file his reply.

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

8 7. Defendants do not oppose an extension up to and including November 11, 2021.

8. Accordingly, Plaintiff shall have until November 11, 2021, to file his reply in support of his Motion to Allow Time For Discovery.

12 || DATED this 5" day of November 2021 DATED this 5" day of November 2021 ||GORDON REES SCULLY FERNANDO HARO III || MANSUKHANI /s/ Dione C. Wrenn /s/ Fernando Haro || ROBERT S. LARSEN, ESQ. FERNANDO HARO III Nevada Bar No. 7785 P.O. Box 81972 |] DIONE C. WRENN, ESQ. Las Vegas, NV 89180 Nevada Bar No. 13285 Plaintiff in Proper Person '? 11300 South 4" Street, Suite 1550 || Las Vegas, Nevada 89101 Attorneys for Defendants, || KRM, Inc, d.b.a. Thomas Keller Restaurant » Group and KVP, LP d.b.a. Bouchon at the Venetian IT IS SO ORDERED 24 □ 6 UNITED STATES MAGISTRATE JUDGE 7 DATED: November 8, 2021