U.S. Equal Employment Opportunity Commission v. PRC INDUSTRIES, INC. CORP

7 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA U.S. EQUAL EMPLOYMENT Case No: 3:23-cv-00135-LRH-CSD OPPORTUNITY COMMISSION, 11 ORDER GRANTING STIPULATION TO EXTEND 12 Plaintiff, TIME FOR DEFENDANT TO v. RESPOND TO MOTION TO 13 INTERVENE (First Request) PRC INDUSTRIES, INC., CORP. d/b/a PRODUCT REMANUFACTURING CENTERS INDUSTRIES, INC., 16 Defendant.

18 Defendant PRC INDUSTRIES, INC., d/b/a PRODUCT REMANUFACTURING CENTERS INDUSTRIES, INC., (“PRC”) by and through its attorney of record, REBECCA BRUCH, ESQ. of LEMONS, GRUNDY & EISENBERG, and THE GEDDES LAW FIRM, by and through its attorney of record, WILLIAM J. GEDDES, attorney of record for Plaintiff-Intervenors Roderick S. Woods and Tashia B. Woods, pursuant to Local Rule IA 6-1, hereby stipulate to extend the time for Defendant to respond to Plaintiff- Intervenors’ Motion to Intervene to May 12, 2023. This requested extension and stipulation is sought in good faith and not for the purposes of delay.

26 /// /// /// 1 MEMORANDUM OF POINTS AND AUTHORITIES I. LEGAL AUTHORITY Fed. R. Civ. P. 6(b)(1) governs the extension of time to respond to Motions. “When an act may or must be done within a specified time, the court may, for good cause, extend the time…” Fed. R. Civ. P. 6(b)(1). The “good cause” standard focuses primarily on the movant’s diligence. Coleman v Quaker Oats Co., 232 F.3d 1271, 1294-95 (9th Cir. 2000).

7 A. Current Status of Complaint.

8 On March 28, 2023, Plaintiff EEOC filed its Complaint. See ECF No. 1. On March 31, 2023, Plaintiff filed a Request for Waiver of Service. See ECF No. 4. On April 7, 2023, Plaintiff-Intervenors filed a Motion to Intervene, and on April 8, 2023, Plaintiff- Intervenors filed a Notice of Erratum. See ECF No. 6 and ECF No. 7. Defendant had not yet made an appearance in this action. On April 12, 2023, Defendant executed the Waiver Of Service Of Summons and it was filed on that same date. See ECF No. 8. Defendant’s Answer is due May 30, 2023. A Response to the Motion to Intervene would have been due on April 21, 2023. Defendants became aware of the Motion to Intervene on April 26, 2023, after the due date for the Response to the Motion to Intervene. See ECF No. 10.

17 In Plaintiff-Intervenors’ Notice of Motion, they noted that they do not oppose allowing Defendant additional time to file a response to Plaintiff-Intervenors’ Motion to Intervene, in order to allow Defendant’s counsel to confer with her clients. Id. 20 Counsel for Plaintiff-Intervenors and Defendant have spoken and stipulate to an extension of time to respond up to and including May 12, 2023.

22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 1 Based on the foregoing, Plaintiff-Intervenors and Defendant request the Court to || approve their stipulation for extension up to and including May 12, 2023.

3 Dated this 27" day of April, 2023.

4 LEMONS, GRUNDY & EISENBERG 6 By: /s/ Rebecca Bruch 7 REBECCA BRUCH, ESQ. (SBN7289) 6005 Plumas St., Third Floor 8 Reno, Nevada 89519 9 Attorneys for Defendant 10 THE GEDDES LAW FIRM 12 By: __/s/ William J. Geddes 13 WILLIAM J. GEDDES, ESQ. (SBN6984) 1575 Delucchi Lane, Suite 206 14 Reno, NV 89502 (775) 853-9455 15 Attorneys for Plaintiff-Intervenors 17 ORDER 18 IT IS SO ORDERED that Defendant’s Response to Plaintiff-Intervenor’s Motion to || Intervene is hereby extended to May 12, 2023.

20 DATED this 1* day of May, 2023.

21 A an h C4 09 LARRY R. HICKS UNITED STATES DISTRICT JUDGE