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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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: (702) 369-6800 Facsimile: (702) 369-6888 Email: suzanne.martin@ogletreedeakins.com 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: (415) 765-9500 Facsimile: (415) 765-9501 Email: shanson@akingump.com 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 20 MY LEFT FOOT CHILDREN’S THERAPY, LLC, et al., 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 [SECOND 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. 26 Pursuant to Local Rule IA 6-1 and 26-4, this is the parties’ second request. The first request 27 was granted on November 22, 2017 (ECF No. 137). Pursuant to the previous request, Defendants’ 28 opposition is currently due on January 2, 2018, and Plaintiffs’ reply is due on January 23, 2018. The 1 JOINT STIPULATION TO EXTEND CASE NO. 2:14-cv-01786-MMD-GWF 1 additional time is necessary because the deposition of Plaintiff, taken on November 28, 2017, was not 2 completed at that time, and the parties have agreed to resume the deposition on December 19, 2017. 3 In addition to the parties’ counsel’s work schedules and the upcoming holiday season, additional time 4 is needed to receive and review the deposition transcript and incorporate it into the briefing. The 5 parties believe that the additional time will be sufficient for both parties to properly brief their 6 positions. This request is made in good faith and not for the purposes of delay. 7 Accordingly, the parties hereby stipulate: 8 The parties agree to extend the time for Defendants to file the opposition to January 18, 2018. 9 The parties agree to extend the time for Plaintiff to file her reply to February 8, 2018. 10 Dated: December 4, 2017 11 IT IS SO STIPULATED: 12 13 14 15 16 17 18 19 20 21 22 23 24 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: 415-765-9500 Fax: 415-765-9501 L. Timothy Terry, Esq. The Terry Law Firm, Ltd 102 N. Curry Street Carson City, NV 89703 tim@theterrylawfirm.com Telephone: (775) 883-2348 Facsimile: (775) 883-2347 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. soswald@employmentlawgroup.com dscher@employmentlawgroup.com awitko@employmentlawgroup.com 888 17th Street, NW, Suite 900 Washington, DC 20006 Telephone: (202) 331-2883 Facsimile: (202) 261-2835 Suzanne L. Martin Ogletree, Deakins, Nash, Smoak, & Stewart, P.C. suzanne.martin@ogletreedeakins.com Wells Fargo Tower 3800 Howard Hughes Pkwy, Suite 1500 Las Vegas, NV 89169 Tel: 702-369-6800 Fax: 702-369-6888 Attorneys for Defendants My Left Foot Children’s Therapy, LLC, Jon Gottlieb and Ann Marie Gottlieb Attorneys for Plaintiff/Relator Mary Kaye Welch ORDER 25 26 IT IS SO ORDERED: 27 4 DATED: December __, 2017 28 By: U.S. DISTRICT JUDGE 2 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 1 CERTIFICATE OF SERVICE Case No. 2:14-cv-01786-MMD-GWF

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