Cummings v. United Healthcare Services, Inc. et al

Filing 112

ORDER Granting 111 Stipulation to Extend Time to File Joint Pretrial Order. Proposed Joint Pretrial Order due by 1/8/2018. Signed by Magistrate Judge George Foley, Jr on 11/30/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:13-cv-00479-APG-GWF Document 111 Filed 11/29/17 Page 1 of 2

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WENDY MEDURA KRINCEK, ESQ., Bar # 6417
MARCUS B. SMITH, ESQ., Bar # 12098
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169-5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
E-mail:
[e-mail]
[e-mail]
Attorneys for Defendant
RAEJOHNE FOSTER

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ANGELA CUMMINGS,

CASE NO. 2:13-CV-00479-APG-GWF

Plaintiff,
vs.
VALLEY HEALTH SYSTEM, LLC, a
Delaware Limited-Liability Company d/b/a
DESERT SPRINGS HOSPITAL;
RAEJOHNE FOSTER, an individual,

STIPULATION TO EXTEND TIME TO
FILE JOINT PRETRIAL ORDER
[SECOND REQUEST]

Defendants.

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Plaintiff, ANGELA CUMMINGS, and Defendant, RAEJOHNE FOSTER, the sole

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remaining defendant, by and through their respective counsel of record, hereby stipulate and agree to

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extend the current deadline to file a Joint Pretrial Order from December 4, 2017, (see ECF No. 109),

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up to and including January 8, 2018.
2017.
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Good cause and excusable neglect exist for the requested extension. Specifically, the parties

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recently attempted to settle this matter at a settlement conference. (See ECF No. 110). Though no

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settlement was reached, the parties have directed their time and resources to achieving a resolution to

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this matter. Due to the impending holiday schedule, and the parties’ continued efforts to resolve this

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case, the parties believe a reasonable extension of time to submit the Joint Pretrial Order

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is warranted. The parties therefore request an extension up to and including January 8, 2018.

LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

Case 2:13-cv-00479-APG-GWF Document 111 Filed 11/29/17 Page 2 of 2

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This is the second request for an extension of this deadline and it is sought in good faith and

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not for the purpose of delay.

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Dated: November 29, 2017

Dated: November 29, 2017

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Respectfully submitted,

Respectfully submitted,

/s/ James P. Kemp
JAMES P. KEMP, ESQ.
KEMP & KEMP, ATTORNEYS AT LAW

/s/ Marcus B. Smith
WENDY MEDURA KRINCEK, ESQ.
MARCUS B. SMITH, ESQ.
LITTLER MENDELSON, P.C.

Attorney for Plaintiff

Attorneys for Defendants

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ORDER

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IT IS SO ORDERED.

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Dated this 30th day of November, 2017.
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_______________________________________
UNITED STATES MAGISTRATE JUDGE

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Firmwide:151470007.1 069080.1036

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LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

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