Jablonski v. Wal-Mart Stores, Inc.

Filing 60

ORDER Granting 59 Stipulation to Extend Deadlines re 58 MOTION for Summary Judgment. Responses due by 6/27/2016. Replies due by 8/4/2016. Signed by Judge Jennifer A. Dorsey on 5/23/16. (Copies have been distributed pursuant to the NEF - ADR)

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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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MARGARET A MCLETCHIE, Nevada Bar No. 10931
ALINA M. SHELL, Nevada Bar No. 11711
MCLETCHIE SHELL LLC
701 East Bridger Ave., Suite 520
Las Vegas, Nevada 89101
[phone]
[e-mail]
Attorneys for Plaintiff, Lidia Jablonski
ROGER L. GRANDGENETT II, ESQ., Nevada Bar No. 6323
LITTLER MENDELSON, P.C.
3960 Howard Hughes Pkwy., Suite 300
Las Vegas, NV 89169
(7020 862-8800
[e-mail]
JAMIE CHU, ESQ., Bar No. 10546
LITTLER MENDELSON, P.C.
2050 Main Street, Suite 900
Irvine, CA 92614
[phone]
[e-mail]
Attorneys for Defendant, Wal-Mart Stores, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LIDIA G. JABLONSKI,

Case No. 2:13-cv-01510-JAD-VCF

Plaintiff,

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WAL-MART STORES, INC.,

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STIPULATION AND ORDER TO
EXTEND THE DEADLINES FOR
FILING RESPONSE AND REPLY
TO DISPOSITIVE MOTIONS

vs.

Defendant.

[FIRST REQUEST]

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[ECF No. 59]

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In compliance with Local Rules 6-1 and 26-4, Plaintiff LIDIA G. JABLONSKI

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(“Plaintiff”) and Defendant WAL-MART STORES, INC. (“Defendant”), by and through

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their attorneys of record, stipulate and agree to extend the time period for Plaintiff Lidia

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Jablonski to file her response to Defendant’s Motion for Summary Judgment, which is

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currently due on May 27, 2016, to be extended to and including June 27, 2016. Further,

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parties also stipulate and agree to extend the time period for Defendant to file its reply to

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Plaintiff’s Response to the Motion for Summary Judgment to and including August 4, 2016.

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This is the first request for an extension of time.
This stipulation is made for good cause, in good faith, and not for purpose of delay.

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This stipulation is necessary because counsel for Plaintiff has deadlines in other matters,

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including a reply in a state post-conviction supplemental petition for a writ of habeas corpus

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due on May 27, 2016, a reply in support of a motion to intervene in United States v. Bundy,

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et al., Dist. Ct. Case No. 2:16-cr-00046-GMN-PAL due on May 31, 2016, an evidentiary

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hearing in a state post-conviction case on June 3, 2016, a hearing on a state post-conviction

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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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supplemental petition for a writ of habeas corpus on June 8, 2016, as well as other deadlines

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in state and federal matters. Additionally, counsel for Defendant has an answering brief due

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with the United States Court of Appeals for the Ninth Circuit due on July 15, 2016, and has

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a planned vacation from July 15, 2016, through July 29, 2016.

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This stipulation is also necessary because the parties are engaging in settlement
conversation. The normal briefing set forth in Local Rule 7-2 will still be applicable.

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Dated: May 20, 2016.

Dated: May 20, 2016.

Respectfully submitted,

Respectfully submitted,

/s/ Alina M. Shell
MARGARET A. MCLETCHIE
ALINA SHELL
MCLETCHIE SHELL LLC

/s/ Jamie Chu, Esq.
ROGER L. GRANDGENETT II, ESQ.
JAMIE CHU, ESQ.
LITTLER MENDELSON, P.C.

Attorneys for Plaintiff
LIDIA G. JABLONSKI

Attorneys for Defendant
WAL-MART STORES, INC.

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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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IT IS SO ORDERED.

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Dated this _23rd__ day of _May____________,

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2016.
____________________________________
Jennifer A. Dorsey
United States District Judge

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