Rivard-Crook et al v. Accelerated Payment Technologies, Inc.

Filing 268

ORDER Granting 267 Stipulation. Proposed Joint Pretrial Order due by 4/4/2016. Signed by Judge Miranda M. Du on 1/27/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:10-cv-02215-MMD-GWF Document 267 Filed 01/26/16 Page 1 of 2

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Marquiz Law Office
Professional Corporation

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3088 Via Flaminia Court
Henderson, NV 89052
Phone: [phone]
Fax: [phone]

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Craig A. Marquiz, Esq.
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NV Bar #7437
[e-mail]

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Attorney for Plaintiffs

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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BARBARA RIVARD-CROOK; BILL CROOK;
RAMON CORONA; MONIQUE DECHAINE;
CHARLES DRAKE, JR.; LENORA HAYES;
RISA HERRERA; NATE IMAHARA; ERIKA
KNAPP; SANDRA LAUE; JOHN
LAWRENCE; ARCELIA MALDONADO;
KELLY STEVENS; RICK WRIGHT,

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Plaintiffs,

Case No. 2:10-cv-02215-MMD-GWF

STIPULATION TO EXTEND THE
PARTIES’ DEADLINE FOR
SUBMISSION OF THEIR JOINT
PROPOSED PRETRIAL
MEMORANDUM BY FORTY-FIVE
(45) DAYS

v.
ACCELERATED PAYMENT
TECHNOLOGIES, INC., a Delaware
Corporation; and DOES 1 through 100, inclusive,

(First Request)

Defendants.

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AND CONSOLIDATED ACTIONS

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The parties, by and through their respective counsel of record, hereby Stipulate to Extend

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the parties’ deadline for submission of their Joint Proposed Pretrial Memorandum by forty-five

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(45) days (i.e., from February 18, 2016 until April 4, 2016). In this regard, given the voluminous

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record at issue (i.e., hundreds of thousands of pages of exhibits and over 45 deposition

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transcripts) and the extensive legal issues that must be summarized for the Court, additional time

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is needed to complete the joint submission. Notably, however, the requested extension will:

Case 2:10-cv-02215-MMD-GWF Document 267 Filed 01/26/16 Page 2 of 2

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(1) enable the parties to meaningfully condense the voluminous record for trial, eliminating

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duplicative exhibits where appropriate; (2) streamline the legal issues that will be presented to

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the jury, including, without limitation, submission of stipulated findings of fact which, in turn,

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should reduce the number of trial days required; and (3) afford the parties several meet and

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confer opportunities whereby they can revisit the appropriateness of participating in another

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settlement conference and/or proceeding with trial.

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RESPECTFULLY SUBMITTED this 26th day of January, 2016.

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Marquiz Law Office

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Weil & Drage, APC

Professional Corporation

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By:

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/s/ Craig A. Marquiz, Esq.
Craig A. Marquiz, Esq.
3088 Via Flaminia Court
Henderson, NV 89052
Attorney for the Rivard-Crook Plaintiffs

By:

/s/ C. Robert Peterson, Esq.
Neil B. Durrant, Esq.
C. Robert Peterson, Esq.
2500 Anthem Village Dr.
Henderson, NV 890052
Attorney for Consolidated Plaintiffs

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Norton Rose Fulbright

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By:

Snell & Wilmer

/s/ Arthur Silbergeld, Esq.
Arthur Silbergeld, Esq.
Jennifer A. Awrey, Esq.
555 South Flower St., 41st Floor
Los Angeles, CA 90071
Attorney for Defendants

By:

/s/ Karl O. Riley, Esq.
Karl O. Riley, Esq.
3883 Howard Hughes Pkwy.
Suite 1100
Las Vegas, NV 890169
Attorney for Defendants

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ORDER
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IT IS SO ORDERED.
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January 27, 2016
DATE: _________________

_____________________________
United States District Court Judge

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