Welch et al v. My Left Foot Children's Therapy, LLC et al

Filing 137

ORDER granting ECF No. 134 Stipulation to Set Briefing Schedule for ECF No. 133 Motion for Partial Summary Judgment. Responses due by 1/2/2018. Replies due by 1/23/2018. Signed by Judge Miranda M. Du on 11/22/2017. (Copies have been distributed pursuant to the NEF - KW)

1
2
3
4

OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
SUZANNE L. MARTIN (Nevada Bar No. 8833)
Wells Fargo Tower, Ste. 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]

5
6
7
8

AKIN GUMP STRAUSS HAUER & FELD LLP
SHAWN HANSON (admitted pro hac vice)
580 California Street, Suite 1500
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]

9
10

Attorneys for Defendants My Left Foot Children’s
Therapy, LLC, Jon Gottlieb, and Ann Marie Gottlieb

11
12
UNITED STATES DISTRICT COURT
13
FOR THE DISTRICT OF NEVADA
14
15

UNITED STATES OF AMERICA AND
THE STATE OF NEVADA ex rel. MARY
KAYE WELCH,

16
Plaintiffs,
17
v.
18
19

MY LEFT FOOT CHILDREN’S
THERAPY, LLC, et al.,

20

Defendants.

21
22

)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. 2:14-cv-01786-MMD-GWF
JOINT STIPULATION AND ORDER TO
SET BRIEFING SCHEDULE FOR
PLAINTIFF’S MOTION FOR PARTIAL
SUMMARY JUDGMENT
[FIRST REQUEST]

The parties, through undersigned counsel, stipulate as set forth herein. Plaintiff Mary Kaye

23

Welch (“Plaintiff”) filed a motion for partial summary judgment on Monday, November 20, 2017

24

(ECF No. 133). The parties have agreed to and propose a briefing schedule for the opposition and

25

reply that differ from the Local Rules. Specifically the parties hereby stipulate:

26

Under the Local Rules, the opposition to the motion for partial summary judgment will be due

27

December 11, 2017. The parties hereby agree to extend the time for Defendants to file the opposition

28

to January 2, 2018.
1
JOINT STIPULATION TO EXTEND
CASE NO. 2:14-cv-01786-MMD-GWF

1

With the opposition due on January 2, 2018, under the Local Rules, the reply would be due on

2

January 16, 2018. The parties hereby agree to extend the time for Plaintiff to file her reply to January

3

23, 2018.

4

Pursuant to Local Rule IA 6-1 and 26-4, this is the parties’ first request. The additional time is

5

necessary due to the parties’ counsel’s work schedules, as well as the upcoming holiday season. The

6

additional time will be sufficient for both parties to properly brief their positions. This request is made

7

in good faith and not for the purposes of delay.

8
9

Dated: November 20, 2017

10

IT IS SO STIPULATED:

11
12
13
14
15
16
17
18
19
20
21
22
23

By:

By:

/s/ David Scher

/s/ Shawn Hanson

Shawn Hanson (admitted pro hac vice)
Akin Gump Strauss Hauer & Feld LLP
580 California Street, Suite 1500
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]

L. Timothy Terry, Esq.
The Terry Law Firm, Ltd
102 N. Curry Street
Carson City, NV 89703
[e-mail]
Telephone: [phone]
Facsimile: [phone]
David Scher (admitted pro hac vice)
R. Scott Oswald (admitted pro hac vice)
Andrew Witko (admitted pro hac vice)
The Employment Law Group, P.C.
[e-mail]
[e-mail]
[e-mail]
888 17th Street, NW, Suite 900
Washington, DC 20006
Telephone: [phone]
Facsimile: [phone]

Suzanne L. Martin
Ogletree, Deakins, Nash, Smoak, & Stewart,
P.C.
[e-mail]
Wells Fargo Tower
3800 Howard Hughes Pkwy, Suite 1500
Las Vegas, NV 89169
Tel: [phone]
Fax: [phone]
Attorneys for Defendants My Left Foot
Children’s Therapy, LLC, Jon Gottlieb and Ann
Marie Gottlieb

Attorneys for Plaintiff/Relator Mary
Kaye Welch

24
ORDER

25
26

IT IS SO ORDERED:

27

22
DATED: November __, 2017

28

By:
U.S. DISTRICT JUDGE
2
JOINT STIPULATION TO EXTEND
CASE NO. 2:14-cv-01786-MMD-GWF

1

CERTIFICATE OF SERVICE

2

United States of America and State of Nevada ex rel. Welch v.
My Left Foot Children's Therapy, LLC, et aL
U. S. District Court of Nevada Case No. 2:14-cv-01786-MMD-GWF

3

I am employed in the County of San Francisco, State of California. I am over the age of 18 and

4
5

not a party to the within action; my business address is: 580 California Street, Suite 1500,

6

San Francisco, California 94104. On November 20, 2017, I served the foregoing document described

7

as:

8

JOINT STIPULATION AND ORDER TO SET BRIEFING SCHEDULE FOR
PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT

9
on the interested parties below, using the following means:
10
11

All parties identified for Notice of Electronic Filing generated by the Court's
CM/ECF system under the above-referenced case caption and number

12
BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an
13
agreement of the parties to accept service by e-mail or electronic transmission, I caused the document
14
to be sent to the respective e-mail addresses of the parties as stated above.
15
I declare that I am employed in the office of a member of the bar of this Court at whose
16
direction the service was made. I declare under penalty of perjury that the foregoing is true and
17
correct. Executed on November 20, 2017, at San Francisco, California.
18
19
20
21

Lorraine France-Gorn

22
23
24
25
26
27
28
1
CERTIFICATE OF SERVICE
Case No. 2:14-cv-01786-MMD-GWF