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

Filing 157

ORDER granting ECF No. 154 Stipulation to Set Briefing Schedule for ECF No. 133 Motion for Partial Summary Judgment. Responses due by 2/1/2018. Replies due by 2/22/2018. Signed by Judge Miranda M. Du on 1/16/2018. (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
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
[THIRD 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’ third request. The first request was

27

granted on November 22, 2017 (ECF No. 137), and the second request was granted on December 4,

28

2017 (ECF No. 150). Pursuant to the previous request, which was needed for the completion of
1
JOINT STIPULATION TO EXTEND
CASE NO. 2:14-cv-01786-MMD-GWF

1

Plaintiff’s deposition on December 19, 2017, Defendants’ opposition is currently due on January 18,

2

2018, and Plaintiffs’ reply is due on February 8, 2018. Defendants have requested, and Plaintiff has

3

agreed to, two additional weeks to file their opposition. This request is made in good faith and not for

4

the purposes of delay. The additional time is necessary due to Defendants’ counsel’s work schedule

5

and because the parties have agreed to request referral to a settlement conference and a 30-day

6

extension of expert discovery deadlines pending the outcome of the conference.

7

Accordingly, the parties hereby stipulate:

8

The parties agree to extend the time for Defendants to file the opposition to February 1, 2018.

9

The parties agree to extend the time for Plaintiff to file her reply to February 22, 2018.

10

Dated: January 16, 2018

11

IT IS SO STIPULATED:

12

By:

13

L. Timothy Terry, Esq.
The Terry Law Firm, Ltd
102 N. Curry Street
Carson City, NV 89703
[e-mail]
Telephone: [phone]
Facsimile: [phone]

14
15
16
17
18
19
20
21
22
23
24

/s/ David Scher

By:

/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]

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

25
26

IT IS SO ORDERED:

27

DATED: January __, 2018
16

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
4

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

5

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

6

San Francisco, California 94104. On January 16, 2018, I served the foregoing document described as:

7
8

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

9
10
11

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

12
13

BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an

14

agreement of the parties to accept service by e-mail or electronic transmission, I caused the document

15

to be sent to the respective e-mail addresses of the parties as stated above.

16

I declare that I am employed in the office of a member of the bar of this Court at whose

17

direction the service was made. I declare under penalty of perjury that the foregoing is true and

18

correct. Executed on January 16, 2018, at San Francisco, California.

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