Mois v. Wynn Las Vegas LLC

Filing 49

ORDER Granting 48 Stipulation to Extend Time. Proposed Joint Pretrial Order due by 5/18/2018. Signed by Judge Andrew P. Gordon on 4/27/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:15-cv-00143-APG-NJK Document 48 Filed 04/26/18 Page 1 of 3

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KAMER ZUCKER ABBOTT
Scott M. Abbott
#4500
Jen J. Sarafina
#9679
Nicole A. Young
#13423
3000 West Charleston Boulevard, Suite 3
Las Vegas, Nevada 89102-1990
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
Wynn Las Vegas, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ELENA MOIS,

)
)
Plaintiff,
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vs.
)
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WYNN LAS VEGAS, LLC, a Nevada Limited )
Liability Company,
)
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Defendant.
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______________________________________ )

Case No. 2:15-cv-00143-APG-NJK
STIPULATION AND REQUEST TO
EXTEND DEADLINE FOR
SUBMISSION OF JOINT PRETRIAL
ORDER
(First Request)

ORDER

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The parties, by and through their respective counsel of record, hereby stipulate and

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request an extension of time to submit their Joint Pretrial Order up to and including May 18,

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2018.

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1.

On April 2, 2018, the Court entered an Order requiring the parties to meet and

confer and submit their Joint Pretrial Order by April 27, 2018 (ECF No. 47).
2.

The parties have made substantial progress toward completing the Pretrial Order.

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However, both counsel for Plaintiff and Defendant have had substantial demands on their

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workload affecting their ability to complete the Pretrial Order. For example, in the past month,

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counsel for Plaintiff have taken approximately over eight (8) depositions in several cases, which

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required travel to California and Reno, and conducted four (4) Early Neutral Evaluation (“ENE”)

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and settlement conferences. Moreover, in the next several weeks, counsel for Plaintiff must

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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Case 2:15-cv-00143-APG-NJK Document 48 Filed 04/26/18 Page 2 of 3

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respond to three (3) pending Motions to Dismiss, a Reply brief to the Nevada Supreme Court,

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and three (3) additional ENE/settlement/mediations. Similarly, counsel for Defendant had over

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five (5) settlement and ENE conferences in the past month, served its civic duty by completing

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jury duty, and conducted over four (4) days of labor negotiations. The labor negotiations will

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continue in the next several weeks, with additional, all-day sessions already scheduled and

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confirmed, and other Answers and briefs are due for various cases.

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3.

Additionally, the case involves over 13,000 documents which the parties have had

to review for the selection of exhibits as required by Local Rule 16-3(b)(8).

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4.

The parties have communicated and met and conferred regarding the content of

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the Pretrial Order numerous times, including written correspondence, teleconferences, and an in-

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person meeting. Indeed, the parties have conferred on April 18, 19, 20, 23, 24, and met for over

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three (3) hours on April 25, 2018.

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5.

This request for an extension is not sought for the purpose of delay or for any

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other improper purpose. Rather, it is sought merely to allow the parties sufficient time to prepare

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the Pretrial Order with the specificity required by Local Rules II 16-3 and II 16-4, and this

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Court’s Order dated April 2, 2018 (ECF No. 47).

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DATED this 26th day of April, 2018.

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KEMP & KEMP

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By:

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KAMER ZUCKER ABBOTT

/s/ Victoria L. Neal
James P. Kemp #6375
Victoria L. Neal #13382
7435 West Azure Drive, Suite 110
Las Vegas, Nevada 89130
Telephone: [phone]
Facsimile: [phone]

By:

/s/ Jen J. Sarafina
Scott M. Abbott
#4500
Jen J. Sarafina
#9679
Nicole A. Young
#13423
3000 West Charleston Blvd., Suite 3
Las Vegas, Nevada 89102
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff

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Attorneys for Defendant
Wynn Las Vegas, LLC

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///

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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Case 2:15-cv-00143-APG-NJK Document 48 Filed 04/26/18 Page 3 of 3

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WHEREFORE the parties Stipulate and request that the deadline for submission of the
Pretrial Order be extended up to and including Friday, May 18, 2018.

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IT IS SO ORDERED.

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Dated: April 27, 2018.

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Dated: _____________________________

_________________________________
UNITED STATES DISTRICT JUDGE

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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