Gooch et al v. Las Vegas Bistro, LLC

Filing 47

ORDER Granting 42 Motion to Extend Dispositive Motion Deadline (Third Request). Motions due by 6/27/2016. Proposed Joint Pretrial Order due by 7/28/2016. Signed by Magistrate Judge Peggy A. Leen on 6/29/2016. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:14-cv-02189-APG-PAL Document 42 Filed 06/24/16 Page 1 of 4

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Matthew J. Hoffer, MI Bar No. P70495*
[e-mail]
SHAFER & ASSOCIATES, P.C.
3800 Capital City Boulevard, Suite 2
Lansing, MI 48906
Tel: [phone]
Fax: [phone]
* Admitted Pro Hac Vice
Elayna J. Youchah, Bar No. 5837
[e-mail]
Phillip Thompson, Bar No. 12114
[e-mail]
JACKSON LEWIS P.C.
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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BRITNEY GOOCH, individually; and
THOMAS IMPASTATO, individually,
Plaintiffs,

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Case No. 2:14-cv-02189-APG-PAL

vs.
LAS VEGAS BISTRO, LLC dba LARRY
FLYNT’S HUSTLER CLUB, a Nevada
limited liability company; DOES I-X; and
ROE BUSINESS ENTITITES I-X, inclusive,

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MOTION TO EXTEND DISPOSITIVE
MOTION DEADLINE
(THIRD REQUEST)

Defendants.

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Pursuant to LR 6-1, 6-2, and LR 26-4, the Defendant, by and through counsel of record,

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hereby request that this Court extend the dispositive motion deadline in the above-captioned case

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by seven (3) days, up to and including June 27, 2016. In support of this Motion, Defendant states

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as follows:

Case 2:14-cv-02189-APG-PAL Document 42 Filed 06/24/16 Page 2 of 4

PRIOR EXTENSIONS:

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1.

On March 30, 2016, the Court entered the parties’ Stipulation and Order to Extend

Discovery Deadlines (First Request), which extended the discovery and dispositive motion
deadline by 30 days. Dkt. No. 39.

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2.

On June 20, 2016, the Court entered the parties’ Stipulation and Order to Extend

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Dispositive Motion Deadline (Second Request), which extended dispositive motion deadline by 7
days. Dkt. No. 41.
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The current dispositive motion deadline is June 24, 2016.

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REASONS FOR REQUEST
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4.

Undersigned counsel for Defendant, Matthew J. Hoffer, has worked diligently

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toward filing Defendant’s motion for summary judgment within the current deadline. However,

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counsel released his support staff for the weekend and is struggling to assemble the Motion,

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Memorandum, and supporting documents in an acceptable fashion. Counsel wishes to assemble

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the documents in an orderly fashion for the Court.
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5.

The requested extension, will, if ultimately necessary, allow counsel support staff to

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assist in finalizing the motion. Nevertheless counsel will labor to file the motion as soon as

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possible.

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6.

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In addition, Counsel for Defendant will seek consent in the present Motion so that

it may be entered as unopposed pursuant to LR IA 6-2

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The following is a list of the current discovery deadlines and the parties’ proposed extended
Deadlines:
Event
Dispositive Motions
Joint Pretrial Order

Current Deadline
June 24, 2016
July 25, 2016, or at least thirty
(30) days after the decision on
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Proposed Deadline
June 27, 2016
July 28, 2016, or at least thirty
(30) days after the decision on

Case 2:14-cv-02189-APG-PAL Document 42 Filed 06/24/16 Page 3 of 4

the last dispositive motion.

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the last dispositive motion.

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WHEREFORE, the Defendant respectfully requests that this Court extend the current
dispositive motion deadline by three (3) days from the current deadline of June 24, 2016, up to

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and including June 27, 2016.
DATED this 24th day of June, 2016.

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JACKSON LEWIS P.C.

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ELAYNA J. YOUCHAH, ESQ.
Nevada Bar No. 5837
PHILLIP THOMPSON, ESQ.
Nevada Bar No. 12114
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Attorneys for Defendant Las Vegas Bistro,
LLC dba Larry Flynt’s Hustler Club

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DATED this 15th day of June, 2016.

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SHAFER &ASSOCIATES, P.C.

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/s/ Matthew J. Hoffer
MATTHEW J. HOFFER, ESQ.
Michigan Bar No. P70495
3800 Capital City Boulevard, Suite 2
Lansing, Michigan 48906
Attorneys for Defendant Las Vegas Bistro,
LLC dba Larry Flynt’s Hustler Club

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ORDER
IT IS SO ORDERED.

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DATED this ___ day of June, 2016.
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U.S. District Court Judge / Magistrate Judge

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