Hicks v. Tesla, Inc.

District Court, D. Nevada

Hicks v. Tesla, Inc.

Trial Court Opinion

1 JOSHUA A. SLIKER, ESQ. Nevada Bar No. 12493 2 JACKSON LEWIS P.C. 3 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 4 Telephone: (702) 921-2460 Facsimile: (702) 921-2461 5 Email: [email protected] 6 Attorney for Defendant Tesla, Inc. 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 CARLOS HICKS, Case No.: 3:23-cv-00220-ART-CSD 11 Plaintiff, STIPULATION AND ORDER 12 EXTENDING TIME FOR DEFENDANT vs. TESLA, INC. TO RESPOND TO 13 TESLA INC.; and DOES 1-10, PLAINTIFF’S COMPLAINT (ECF No. 1) 14 Defendants. (FIRST REQUEST) 15 Defendant Tesla, Inc. (“Tesla” Or “Defendant”), by and through its counsel of record, the 16 law firm of Jackson Lewis P.C., and Plaintiff Carlos Hicks (“Plaintiff”), by and through his counsel 17 of record, the law firm of McCracken, Stemerman & Holsberry, hereby stipulate and agree to extend 18 the time for Defendant Tesla, Inc. to file its response to Plaintiff’s Complaint (ECF No. 1) up to 19 and including July 5, 2023 based on the following: 20 1. This is the first stipulation to extend the time for Defendant to respond to Plaintiff’s 21 Complaint. 22 2. Defendant was served with the Summons and Complaint on May 31, 2023 making 23 Defendant’s response to Plaintiff’s Complaint currently due on June 21, 2023. 24 3. Defendant asserts that Plaintiff and Defendant are party to a written agreement 25 which provides that all disputes arising out of or related to Plaintiff’s employment with Defendant 26 are subject to resolution by final and binding arbitration. 27 1 4. The parties have agreed to extend the deadline for Defendant to file its response te 2 || the Complaint to July 5, 2023 to allow Plaintiff sufficient time to evaluate Defendant’s informatio: 3 || and request. The parties believe these circumstances constitute good cause for granting an □□□□□□□□□ 4 ||to permit the parties to explore whether they can avoid motion practice related to the □□□□□□□□□□□ 5 || issue, conserving Judicial resources. See Fed. R. Civ. P. 6(b)(1). 6 5. The parties are not waiving, relinquishing, or otherwise impairing any claim 7 || defense, argument, or other right they may have by virtue of entering into this Stipulation. Szant 8 || v. Marina Marketplace 1, LLC, No. 3:11-cv-00394-RCJ-VPC,

2013 U.S. Dist. LEXIS 168028

, a 9 || *10 (D. Nev. Nov. 26, 2013). 10 Dated this 21% day of June, 2023. Il |] McCRACKEN, STEMERMAN & JACKSON LEWIS P.C. HOLSBERRY 13 || 4s/Sarah Grossman-Swenson /s/ Joshua A. Sliker SARAH GROSSMAN-SWENSON, ESQ. JOSHUA A. SLIKER, ESQ 14 || Nevada Bar No. 11979 Nevada Bar No. 12493 1630 S. Commerce Street, Suite A-1 300 S. Fourth Street, Suite 900 1D || Las Vegas, Nevada 89102 Las Vegas, Nevada 89101 16 Attorneys for Plaintiff Carlos Hicks Attorneys for Defendant Tesla, Inc. 17 18 19 ORDER IT IS SO ORDERED. 20 CS United States Magisifaffe Judge 23 Date: June 22, 2023 24 25 26 27 28

Reference

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