Dualan et al v. Jacob Transportation Services, LLC

Filing 49

ORDER Granting 48 Stipulation for Extension of Time to File Joint Pretrial Order. Proposed Joint Pretrial Order due by 5/10/2015. Signed by Magistrate Judge Nancy J. Koppe on 4/13/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:14-cv-01135-JAD-NJK Document 48 Filed 04/10/15 Page 1 of 3

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MARK J. BOURASSA, ESQ.
Nevada Bar No. 7999
TRENT L. RICHARDS, ESQ.
Nevada Bar No. 11448
THE BOURASSA LAW GROUP, LLC
8668 Spring Mountain Road, Suite 101
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
[e-mail]
Attorneys for Plaintiffs Leonardo Dualan, Zoltan
Nemeth and Jamin Vergara
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
***
LEONARDO
DUALAN,
VALERIE ) CASE NO.: 2:14-cv-01135-JAD-NJK
KALEIKINI, ZOLTAN NEMETH, and JAMIN )
VERGARA, individually and on behalf of those ) STIPULATION FOR EXTENSION OF TIME
similarly situated,
) TO FILE A JOINT PRETRIAL ORDER
)
Plaintiffs;
) (FIRST REQUEST)
)
v.
)
)
JACOB TRANSPORTATION SERVICES, LLC, )
a Nevada Limited Liability Company, D/B/A )
EXECUTIVE LAS VEGAS,
)
)
Defendant.
)
)

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COMES NOW, Plaintiffs, Leonardo Dualan, Zoltan Nemeth and Jamin Vergara, (“Plaintiffs”)

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and Defendant, Jacob Transportation Services, LLC d/b/a Executive Las Vegas (“Defendant”), by and

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through their respective counsel of record, and hereby request that this Court enter an order extending

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the deadline for the parties to file their joint pretrial order set forth in the Joint Discovery Plan and

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Scheduling Order [Document 18] pursuant to Fed. R. Civ. P. 16(b)(4). It is hereby stipulated as

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follows:

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1.

Plaintiffs filed their Complaint on July 10, 2014.

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Case 2:14-cv-01135-JAD-NJK Document 48 Filed 04/10/15 Page 2 of 3

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2.

On September 19, 2014, the Court filed the Joint Discovery Plan and Scheduling Order,

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which set forth, among other things, the deadline to file the joint pretrial order Friday, April 10, 2015.

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[Document 18].

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3.

No trial date has been set in this case.

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4.

Since the Court filed the Joint Discovery Plan and Scheduling Order, the parties have

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been actively conducting discovery during the first phase of discovery, which focused on Plaintiffs’

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individual claims and discovery relating to class certification.

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5.

The parties have also used this time to enter into voluntary settlement discussions.

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6.

The parties now wish to engage in additional settlement discussions within the next 30

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days, i.e., before May 10, 2015.

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7.

The parties agree that it is reasonable to briefly defer the cost and time required in

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moving forward with a motion for class certification and/or preparing for a trial on the individual

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claims.

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8.

The parties agree that the extensions requested will not operate as a prejudice to any of

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the parties, and that this request to modify the current deadline is made with good cause, is in the

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interests of justice and judicial efficiency.

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Case 2:14-cv-01135-JAD-NJK Document 48 Filed 04/10/15 Page 3 of 3

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9.

Therefore, the parties hereby stipulate and request that this Court enter an Order

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extending the deadline to file the parties’ joint pretrial order from April 10, 2015 to May 10, 2015.

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AGREED AND ACCEPTED:

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Plaintiffs:

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DATED this 10th day of April, 2015.

DATED this 10th day of April, 2015.

THE BOURASSA LAW GROUP, LLC.

JIMMERSON HANSEN, PC

By: Mark J. Bourassa, Esq.
MARK J. BOURASSA, ESQ.
Nevada Bar No. 7999
TRENT L. RICHARDS, ESQ.
Nevada Bar No. 11448
8668 Spring Mountain Rd., Suite 101
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Leonardo Dualan,
Zoltan Nemeth and Jamin Vergara

By: Meredith L. Holmes, Esq.
LYNN M. HANSEN, ESQ.
Nevada Bar No. 00244
MEREDITH L. HOLMES, ESQ.
Nevada Bar No. 11602
JAMES J. JIMMERSON, ESQ.
Nevada Bar No. 00264
415 South 6th Street, Suite 100
Las Vegas NV 89101
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant

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Defendant:

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED: April 13, 2015
CASE NO.: 2:14-cv-01135-JAD-NJK

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