Case 3:25-cv-00137-ART-CSD Document 6 Filed 03/11/25 Page 1 of 2
`
`Deverie J. Christensen
`Nevada State Bar No. 6596
`JACKSON LEWIS P.C.
`300 South Fourth Street, Suite 900
`Las Vegas, Nevada 89101
`Tel: (702) 921-2460
`Email: deverie.christensen@jacksonlewis.com
`Attorney for Defendant
`Tesla, Inc. fka Tesla Motors, Inc.
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`Case No. 3:25-cv-00137-ART-CSD
`
`MALCOLM SHEPHERD,
`Plaintiff,
`
`vs.
`TESLA, INC., (a.k.a. TESLA MOTORS, INC.)
`a Delaware Corporation; DOES I-X; and, ROE
`Business Entities I-X,
`Defendants.
`
`ORDER GRANTING
`STIPULATION TO EXTEND
`DEADLINE FOR DEFENDANTS
`TO RESPOND TO PLAINTIFF’S
`COMPLAINT
`(FIRST REQUEST)
`
`IT IS HEREBY STIPULATED by and between Plaintiff Malcolm Shepherd, (“Plaintiff”),
`by and through his counsel, Kemp & Kemp, and Defendant, Tesla, Inc. fka Tesla Motors, Inc.
`(“Defendant”), by and through their counsel, the law firm of Jackson Lewis P.C., that Defendant
`shall have an extension up to and including March 28, 2025, in which to file its response to
`Plaintiff’s Complaint. This Stipulation is submitted and based upon the following:
`Plaintiff filed his Complaint on November 29, 2024 in the District Court, Clark
`1.
`County Nevada, Case No. A-24-907076-C. The Summons and Complaint were served on
`Defendant on or about February 14, 2025.
`2.
`On March 7, 2025, the Defendant filed a Notice to Federal Court of Removal of
`Civil Action from State Court, Case No. 3:25-cv-00137-ART-CSD.
`3.
`Defendant’s response to the Complaint, following removal, is due on March 14,
`
`2025.
`
`Undersigned Defense Counsel represents Tesla Inc. in an unrelated arbitration case
`4.
`pending before JAMS and for which Plaintiff’s counsel represents the claimant in that arbitration
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`Case 3:25-cv-00137-ART-CSD Document 6 Filed 03/11/25 Page 2 of 2
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`case. Both Counsels are preparing for an arbitration hearing that begins on March 31, including
`meeting and conferring regarding exhibits, witnesses, objections, and other matters for which
`deadlines are fast approaching in the next two weeks.
`5.
`Accordingly, Undersigned Defense Counsel needs additional time to prepare a
`response to the complaint filed in this case, and requested Plaintiff agree to a two-week extension
`to March 28, 2025. Plaintiff has kindly agreed to the requested extension.
`6.
`Thus, the parties hereby stipulate to extend the deadline to March 28, 2025, for
`Defendant to file its response to the Complaint.
`7.
`This is the first request for an extension of time for Defendant to file its response to
`Plaintiff’s Complaint.
`8.
`This Stipulation is made in good faith and not for the purpose of delay.
`9.
`Nothing in this Stipulation and Order shall operate to waive, relinquish, or impair
`any claim, defense, objection, or right of any party in this case. Further, nothing in this Stipulation
`and Order shall be construed as an admission of or consent to the merit or validity of any claim,
`defense, objection, or right by any party in this case.
`Dated this 11th day of March, 2025.
`KEMP & KEMP
`
`JACKSON LEWIS P.C.
`
`/s/ James P. Kemp
`James P. Kemp, Esq., Bar #6375
`7435 W. Azure Drive, Ste. 110
`Las Vegas, Nevada 89130
`Attorney for Plaintiff
`Malcolm Shepherd
`
`/s/ Deverie J. Christensen
`Deverie J. Christensen, Bar # 6596
`300 South Fourth Street, Suite 900
`Las Vegas, Nevada 8910
`Attorney for Defendant
`Tesla, Inc. fka Tesla Motors, Inc.
`
`ORDER
`IT IS SO ORDERED.
`
`United States Magistrate Judge
`Dated:
`
`March 11, 2025.
`
`4907-6867-5110, v. 1
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