Steward v. CMRE Financial Services, Inc.

Filing 60

ORDER Granting 59 Stipulation to Extend Time to Respond to 55 Motion for Summary Judgment. Response due by 3/3/2017. Reply due by 3/17/2017. Signed by Judge Jennifer A. Dorsey on 2/23/2017. (Copies have been distributed pursuant to the NEF - DC)

Case 2:15-cv-00408-JAD-NJK Document 59 Filed 02/23/17 Page 1 of 2

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MARK J. BOURASSA, ESQ.
Nevada Bar No. 7999
TRENT L. RICHARDS, ESQ.
Nevada Bar No. 11448
THE BOURASSA LAW GROUP
7575 Vegas Drive, Suite 150
Las Vegas, Nevada 89128
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Case No.: 2:15-cv-00408-JAD-NJK

HILARY STEWARD, on behalf of herself and
those similarly situated,

AMENDED STIPULATION TO
EXTEND TIME TO FILE
RESPONSIVE PLEADING TO
DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT

Plaintiff,
vs.
CMRE FINANCIAL SERVICES, INC., a
California corporation; HEALTHCARE
REVENUE MANAGEMENT GROUP, a/k/a
HRMG, an entity of unknown form,
Defendants.

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Plaintiff HILARY STEWARD (“Plaintiff”) by and through her attorneys of record, Mark

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J. Bourassa, Esq. and Trent L. Richards, Esq. of the Bourassa Law Group, and Defendants CMRE

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FINANCIAL SERVICES, INC. and HEALTHCARE REVENUE MANAGEMENT GROUP
a/k/a HRMG (“Defendants”) by and through their attorneys of record, Jeanne L. Zimmer, Esq.
and J. Grace Felipe, Esq. of Carlson & Messer, LLP, hereby submit this Stipulation for Extension
of Time to File a Responsive Pleading to Defendants’ Motion for Summary Judgment.
1. Defendants refiled their Motion for Summary Judgment on or about February 3, 2017
pursuant to the Court’s order dated January 27, 2017.
2. Plaintiff currently has until February 24, 2017 to file a response to Defendants’ Motion

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Case 2:15-cv-00408-JAD-NJK Document 59 Filed 02/23/17 Page 2 of 2

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for Summary Judgment.
3. Plaintiff’s counsel is about to begin a trial that is expected to take place February 21, 2017
through February 24, 2017.
4. Therefore, the parties stipulate that Plaintiff’s response to Defendants’ Motion for
Summary Judgment will now be due on or before Friday, March 3, 2017.
5. The parties further stipulate that Defendants’ reply will now be due on or before Friday,

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March 17, 2017.

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This is the parties’ first request for extension of these deadlines, and is not intended to

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cause any delay or prejudice to any party.

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DATED this 23rd day of February, 2017

DATED this 23rd day of February 2017

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BOURASSA LAW GROUP

CARLSON & MESSER, LLP

By: /s/ Mark J. Bourassa, Esq.
MARK J. BOURASSA, ESQ.
Nevada Bar No. 7999
TRENT L. RICHARDS, ESQ.
Nevada Bar No. 11448
7575 Vegas Drive, Suite 150
Las Vegas, Nevada 89128
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

By: /s/ J. Grace Felipe, Esq.
JEANNE L. ZIMMER, ESQ.
Pro Hac Vice
J. GRACE FELIPE, ESQ.
Pro Hac Vice
5959 W Century Blvd, Suite 1214
Los Angeles, CA 90045
Telephone: [phone]
Attorneys for Defendants

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IT IS SO ORDERED.
Dated: February 23, 2017.
DATED this ____ day of _______________, 2017.

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___________________________________
UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
Case No.: 2:15-cv-00408-JAD-NJK

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