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

Filing 150

ORDER approving ECF No. 147 Stipulation re ECF No. 133 Motion for Partial Summary Judgment. Response due by 1/18/2018. Reply due by 2/8/2018. Signed by Judge Miranda M. Du on 12/4/2017. (Copies have been distributed pursuant to the NEF - KR)

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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]

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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]

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

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

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

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

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

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

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

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reply that differ from the Local Rules.

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

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was granted on November 22, 2017 (ECF No. 137). Pursuant to the previous request, Defendants’

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opposition is currently due on January 2, 2018, and Plaintiffs’ reply is due on January 23, 2018. The
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JOINT STIPULATION TO EXTEND
CASE NO. 2:14-cv-01786-MMD-GWF

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additional time is necessary because the deposition of Plaintiff, taken on November 28, 2017, was not

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completed at that time, and the parties have agreed to resume the deposition on December 19, 2017.

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In addition to the parties’ counsel’s work schedules and the upcoming holiday season, additional time

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is needed to receive and review the deposition transcript and incorporate it into the briefing. The

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parties believe that the additional time will be sufficient for both parties to properly brief their

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positions. This request is made in good faith and not for the purposes of delay.

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Accordingly, the parties hereby stipulate:

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The parties agree to extend the time for Defendants to file the opposition to January 18, 2018.

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The parties agree to extend the time for Plaintiff to file her reply to February 8, 2018.

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Dated: December 4, 2017

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IT IS SO STIPULATED:

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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
ORDER

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IT IS SO ORDERED:

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DATED: December __, 2017

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

Case 2:14-cv-01786-MMD-GWF Document 147 Filed 12/04/17 Page 3 of 3

CERTIFICATE OF SERVICE
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

I am employed in the County of San Francisco, State of California. I am over the age of 18 and
not a party to the within action; my business address is: 580 California Street, Suite 1500,
San Francisco, California 94104. On December 4, 2017, I served the foregoing document described
as:
JOINT STIPULATION AND ORDER TO SET BRIEFING SCHEDULE FOR
PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT [SECOND
REQUEST]
on the interested parties below, using the following means:
All parties identified for Notice of Electronic Filing generated by the Court's
CM/ECF system under the above-referenced case caption and number
BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the document
to be sent to the respective e-mail addresses of the parties as stated above.
I declare that I am employed in the office of a member of the bar of this Court at whose
direction the service was made. I declare under penalty of perjury that the foregoing is true and
correct. Executed on December 4, 2017, at San Francisco, California.

Lorraine France-Gorn

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CERTIFICATE OF SERVICE

Case No. 2:14-cv-01786-MMD-GWF