Krause v. Nevada Mutual Insurance Company et al

Filing 97

ORDER Granting 95 Motion to Extend Time to Repond re 80 MOTION for Sanctions. Responses due by 6/20/2013. Signed by Magistrate Judge Carl W. Hoffman on 6/11/13. (Copies have been distributed pursuant to the NEF - MMM)

1 Kathleen J. England, NV Bar #206
ENGLAND LAW OFFICE
2 630 S. Third Street
Las Vegas NV 89101
3 [phone]
[e-mail]
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Melanie A. Hill, NV Bar #8796
5 LAW OFFICE OF MELANIE HILL
9345 W. Sunset Road, Suite 100
6 Las Vegas, NV 89148
[phone]
7 [phone] (fax)
[e-mail]
8 Attorneys for Plaintiff, Sandra K. Krause
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ENGLAND LAW OFFICE

ATTORNEYS AT LAW
630 SOUTH THIRD STREET
LAS VEGAS, NEVADA 89101
[phone] ‚ FAX [phone]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SANDRA K. KRAUSE,

)
)
Plaintiff,
)
)
vs.
)
)
NEVADA MUTUAL INSURANCE
COMPANY and TREAN CORPORATION, )
)
)
Defendants.

Case No.: 2:12-cv-00342-JCM-CWH
STIPULATION FOR EXTENSION FOR
PLAINTIFF TO FILE HER OPPOSITON
TO DEFENDANTS’ RULE 37(b)
MOTION FOR SANCTIONS AND
CONTEMPT [Dkt. 80]
(First Request)

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Defendants filed their Rule 37(b) Motion for Sanctions and Contempt [Dkt. 80] on the

22 Friday before Memorial Day weekend, May 24, 2013, and it was filed under seal. As a result of
23 the filing under seal, counsel for Defendants mailed the Motion to counsel and it wasn’t received
24 by the undersigned until the following Wednesday, May 29, five days after it was filed due to the
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holiday weekend.
The justification for said extension is that Plaintiffs lead counsel who is handling this matter

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along with co-counsel will be unable to complete Plaintiff’s opposition to Defendants Motion for
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1 Sanctions and Contempt because Ms. England has been out of state on State Bar of Nevada
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business since Thursday, June 6, and she did not return until Sunday, June 9, 2013. Upon her
return, and in addition to this opposition and other oppositions and a reply plaintiff’s counsel are

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preparing in this case, counsel are preparing for two separate depositions in another case.
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Like Ms. England, Ms. Hill is a sole practitioner and had to attend to other pressing case

7 commitments in a few of her federal criminal cases over the last week and a half and she has been
8 unable to complete the opposition. Additionally, due to the nature of the motion, additional time
9 is necessary to properly and completely oppose the Motion for Sanctions and Contempt and a
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ENGLAND LAW OFFICE

ATTORNEYS AT LAW
630 SOUTH THIRD STREET
LAS VEGAS, NEVADA 89101
[phone] ‚ FAX [phone]

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modest ten day extension of the deadline is warranted.
At the request of Plaintiff's counsel, and as a professional courtesy among counsel, the

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parties agree to allow the Plaintiff a ten (10) day extension of time to file her opposition to

14 Defendants Motion for Sanctions and Contempt. Plaintiff respectfully requests that the Court
15 grant this stipulation allowing the Plaintiff an additional ten days (10) from Monday, June 10,
16 2013 to and including Thursday, June 20, 2013. This modest extension would not unduly delay
17 or prejudice anyone in this matter and is warranted under the circumstances and based on the
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current procedural posture of this case.
THERFORE, THE PARTIES HERERBY STIPULATE AND AGREE that the time for

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Plaintiff to file her opposition to Defendants Motion for Sanctions and Contempt be extended for

22 ten days from Monday, June 10, 2013 to and including Thursday, June 20, 2013.
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Respectfully submitted: June 10, 2013.

24 By: /s/ Melanie A. Hill
Melanie A. Hill
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Law Office of Melanie Hill
9345 W. Sunset Rd., Suite 100
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Las Vegas, NV 89148
Attorneys for Plaintiff,
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Sandra K. Krause
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By: /s/ Shannon McDonough
Shannon M. McDonough
Lisa Bachman
Fafinski Mark & Johnson, P.A.
775 Prairie Center Drive, Suite 400
Eden Prairie, MN 55344
Attorneys for Defendants TREAN and NMIC

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Case 2:12-cv-00342-JCM-CWH Document 96 Filed 06/10/13 Page 3 of 3

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ORDER
Based on the foregoing Stipulation of the parties and good cause appearing,
IT IS HEREBY ORDERED that the time for Plaintiff to file her opposition to Defendants

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Motion for Sanctions and Contempt be extended for ten days from Monday, June 10, 2013 to and
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including Thursday, June 20, 2013.
11th
DATED this ______ day of June, 2013.
_________________________________
U.S. Magistrate Judge Carl W. Hoffman

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ENGLAND LAW OFFICE

ATTORNEYS AT LAW
630 SOUTH THIRD STREET
LAS VEGAS, NEVADA 89101
[phone] ‚ FAX [phone]

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