Andrew et al v. Century Surety Company

Filing 284

ORDER granting 283 Stipulation; Motions for Reconsideration due by 7/17/2019. Signed by Judge Andrew P. Gordon on 7/8/2019. (Copies have been distributed pursuant to the NEF - JM)

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DENNIS M. PRINCE, ESQ.
Nevada Bar No. 5092
PRINCE LAW GROUP
8816 Spanish Ridge Ave.
Las Vegas, Nevada 89148
Tel.: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
DANA ANDREW, as Legal Guardian of
RYAN T. PRETNER, and RYAN T. PRETNER,
individually,

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Plaintiffs,
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vs.
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CENTURY SURETY COMPANY, a foreign
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Corporation; MEADOWBROOK INSURANCE
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GROUP, a foreign corporation; and DOES I through )
X, inclusive,
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Defendants.
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____________________________________________)

CASE NO.: 2:12-cv-00978-APG-PAL

STIPULATION AND ORDER
TO EXTEND DEADLINE TO FILE
MOTIONS FOR
RECONSIDERATION

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IT IS HEREBY STIPULATED AND AGREED between Plaintiffs DANA ANDREW, as

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legal guardian on behalf of Ryan T. Pretner, and RYAN T. PRETNER, through their counsel of

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record, Dennis M. Prince, Esq. and Kevin T. Strong, Esq. of PRINCE LAW GROUP, and Defendant

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CENTURY SURETY COMPANY, through its counsel of record, Maria Louise Cousineau, Esq. of

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COZEN O’CONNOR; J. Ric Gass, Esq., David J. Turek, Esq., and Stephen T. Trigg, Esq. of GASS

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Prince Law Group
8816 Spanish Ridge
Las Vegas, NV 89148

WEBER MULLINS LLC; and Martin J. Kravitz, Esq. of CHRISTIAN, KRAVITZ, DICHTER,
JOHNSON & SLUGA, LLC, that the deadline for the parties to file their respective motions for
reconsideration shall be continued from July 1, 2019 to July 17, 2019. The current deadline for the
parties to file their respective motions for reconsideration is July 1, 2019, which the Court set in its
May 31, 2019 Scheduling Order (ECF No. 280).
The primary purpose for the parties’ requested stipulation is that lead counsel for Plaintiffs,
Dennis M. Prince, Esq., devoted substantial time and resources in June to establish his new law

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practice. While Mr. Prince continues to transition several cases from his previous law office to his

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new law office, this process is nearly complete. Additionally, Kevin T. Strong, Esq., who is also

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counsel for Plaintiffs, took an extended period away from the office during June to celebrate his

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wedding, which took place on June 15, 2019 and honeymoon, which took place the week thereafter.

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Counsel for Defendant Century Surety Company has graciously agreed to a sixteen (16) day extension

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through and until July 17, 2019 for the parties to file their respective motions for reconsideration.
This is the first extension requested in connection with the motions for reconsideration.
Considering these circumstances and pending the Court’s approval, the parties respectfully
request this Court to approve the foregoing stipulation.
DATED this 28th day of June, 2019.

DATED this 28th day of June, 2019.

PRINCE LAW GROUP

GASS WEBER MULLINS

/s/ Dennis M. Prince
DENNIS M. PRINCE, ESQ.
Nevada Bar No. 5092
8816 Spanish Ridge Ave.
Las Vegas, NV 89148
Attorneys for Plaintiffs

/s/ David J. Turek
DAVID J. TUREK, ESQ. (Pro Hac Vice)
STEPHEN T. TRIGG, ESQ. (Pro Hac Vice)
RIC GASS, ESQ. (Pro Hac Vice)
241 North Broadway, Suite 300
Milwaukee, WI 53202

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KRAVITZ, SCHNITZER & JOHNSON
MARTIN J. KRAVITZ, ESQ.
Nevada Bar No. 0083
8985 S. Eastern Ave., Suite 200
Las Vegas, NV 89123

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COZEN O’CONNOR
MARIA LOUISE COUSINEAU(Pro Hac Vice)
601 S. Figueroa Street, Suite 3700
Los Angeles, CA 90017

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Attorneys for Defendant

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ORDER

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IT IS SO ORDERED.

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Dated: this 8, 2019.
DATED July _____ day of ____________, 2019.

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Prince Law Group
8816 Spanish Ridge
Las Vegas, NV 89148

______________________________________
UNITED STATES DISTRICT COURT JUDGE
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