Hill v. Petco Animal Supplies Stores, Inc.

1 JOSHUA A. SLIKER, ESQ.

Nevada Bar No. 12493 JACKSON LEWIS P.C.

3 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 Telephone: (702) 921-2460 Facsimile: (702) 921-2461 Email: [email protected] Attorney for Defendant Petco Animal Supplies Stores, Inc. 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA KISHA HILL, Case No.: 2:23-cv-01002-RFB-VCF Plaintiff, STIPULATION AND ORDER 12 EXTENDING TIME FOR DEFENDANT vs. TO RESPOND TO PLAINTIFF’S PETCO ANIMAL SUPPLIES STORES, INC., COMPLAINT (ECF No. 1-1) a Foreign Corporation Licensed to do Business in Nevada, (FIRST REQUEST) Defendant.

Defendant Petco Animal Supplies Stores, Inc. (“Petco” Or “Defendant”), by and through its counsel of record, the law firm of Jackson Lewis P.C., and Plaintiff Kisha Hill (“Plaintiff”), by and through her counsel of record, the Law Office of Mary F. Chapman, Ltd., hereby stipulate and agree to extend the time for Defendant Petco to file its response to Plaintiff’s Complaint (ECF No. 1-1) up to and including July 28, 2023 based on the following: 1. This is the first stipulation to extend the time for Defendant to respond to Plaintiff’s Complaint.

2. Defendant was served with the Summons and Complaint on June 8, 2023 and removed the case to this Court on June 29, 2023 (ECF No. 1), making Defendant’s response to Plaintiff’s Complaint currently due on July 6, 2023.

3. Defendant asserts that Plaintiff and Defendant are party to a written agreement are subject to resolution by final and binding arbitration.

2 4. The parties have agreed to extend the deadline for Defendant to file its response to the Complaint to July 28, 2023 to allow Plaintiff sufficient time to evaluate Defendant’s information and request. Plaintiff’s counsel will be out of the office from July 6 to July 16 and will also need time to consult with Plaintiff and her co-counsel.

6 5. The parties believe these circumstances constitute good cause for granting an extension to permit the parties to explore whether they can avoid motion practice related to the arbitration issue, conserving judicial resources. See Fed. R. Civ. P. 6(b)(1).

9 6. The parties are not waiving, relinquishing, or otherwise impairing any claim, defense, argument, or other right they may have by virtue of entering into this Stipulation. Szanto v. Marina Marketplace 1, LLC, No. 3:11-cv-00394-RCJ-VPC, 2013 U.S. Dist. LEXIS 168028, at *10 (D. Nev. Nov. 26, 2013).

13 Dated this 5th day of July, 2023.

14 LAW OFFICES OF MARY F. CHAPMAN, JACKSON LEWIS P.C.

LTD. /s/ Mary F. Chapman /s/ Joshua A. Sliker MARY F. CHAPMAN, ESQ. JOSHUA A. SLIKER, ESQ Nevada Bar No. 6591 Nevada Bar No. 12493 8440 W. Lake Mead Blvd., Suite 203 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89128 Las Vegas, Nevada 89101 Attorneys for Plaintiff Kisha Hill Attorneys for Defendant 20 Petco Animal Supplies Stores, Inc. ORDER 22 IT IS SO ORDERED. __________________________ United States District Judge / 25 United States Magistrate Judge 26 Date: ___7_-_5_-2_0_2_3_____________ 4853-8212-3886, v. 2