Bouch v. Eldorado Resorts Corporation et al

Filing 67

ORDER Granting 66 Stipulation to Extend Time. See Order for deadlines. Signed by Magistrate Judge Peggy A. Leen on 2/10/17. (Copies have been distributed pursuant to the NEF - MR) (Main Document 67 replaced on 2/10/2017) (MR).

1
2
3
4
5
6
7
8

10
11
Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

9

ANTHONY L. MARTIN, ESQ.
Nevada Bar No. 8177
[e-mail]
JILL GARCIA, ESQ.
Nevada Bar No. 7805
[e-mail]
SHELLEY L. MURRAY, ESQ.
Nevada Bar No. 12831
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Wells Fargo Tower
Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]
Fax: [phone]
Attorneys for Defendants Eldorado Resorts Corporation
and Michael Marrs

12

UNITED STATES DISTRICT COURT

13

FOR THE DISTRICT OF NEVADA

14
15

TERESA LEIGH BOUCH,
Plaintiff,

16
17

vs.

18

ELDORADO RESORTS CORPORATION, a
Florida corporation; MICHAEL MARRS;
BRUCE POLANSKY; KRISTEN BECK;
DOMINIC TALEGHANI; JAMES GRIMES;
AND DOES 1-50, inclusive;

19
20
21
22

Case No.: 2:15-cv-01023-RFB-PAL

STIPULATION AND ORDER TO
EXTEND TIME TO FILE DISPOSITIVE
MOTIONS AND RESPONSES AND
REPLIES THERETO
(SECOND REQUEST)

Defendants.
Pursuant to LR IA 6-1, LR IA 6-2, LR 7-1 and LR 26-4, Plaintiff Teresa Leigh Bouch

23
24

(“Plaintiff”) and Defendants Eldorado Resorts Corporation and Michael Marrs (collectively

25

“Defendants”), by and through their undersigned counsel, hereby stipulate and agree to this second

26

request for extension of time for the parties to file dispositive motions in this action, along with

27

related responses and replies. Pursuant to the Court's December 28, 2016, Order to Extend Time

28

1

To File Dispositive Motions and Responses and Replies Thereto (ECF No. 61), the current

2

deadline for filing dispositive motions in this case is March 16, 2017, (see id. at 2). The parties

3

have completed all discovery in this matter and good cause exists for the proposed extension based

4

upon the following:

5
6

As the Court is aware, this case is one of thirty-three related lawsuits sitting before this
Court. Recognizing the complexity of litigating these lawsuits simultaneously, the parties agreed

7
8

to divide the cases into five groups and stagger deadlines in order to streamline the litigation
process and avoid overlapping dispositive motion deadlines. Defendants filed Motions for

10

Summary Judgment on September 1, 2016 and September 15, 2016, in Group II

11
Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

9

cases. Unfortunately, response and reply briefing had been delayed and was not completed until

12

January 30, 2017. Although the parties continue to conduct discovery, it is apparent that the prior

13

delays will make it difficult to comply with the current briefing schedule for the remaining

14
15
16
17

matters. Accordingly, the parties hereby stipulate to adjust the briefing schedule in the manner
presented below in an effort to allow the parties an aggressive, yet realistic approach to complete
all pre-trial activity in the related actions.

18
19

Based upon the foregoing, the parties have agreed that the dispositive motion deadlines should
be extended by seven (7) days in the following manner:

20




21
22

Defendants shall file their dispositive motion no later than March 23, 2017;
Plaintiff shall file any response to Defendants’ dispositive motions no later than
April 24, 2017;

23


24
25

//

26

Defendants shall file their reply no later than May 24, 2017.

//

27

//

28
2

1
2
3

This stipulation is not brought for purposes of delay or any other improper purpose.
Dated this 8th day of February, 2017.
WATKINS & LETOFSKY, LLP

OGLETREE, DEAKINS, NASH, SMOAK
& STEWART, P.C.

/s/ Daniel R. Watkins
Daniel R. Watkins
Brian S. Letofsky
8215 South Eastern Avenue
Suite 265
Las Vegas, NV 89123
Telephone: [phone]
Attorneys for Plaintiff Teresa Leigh Bouch

/s/ Jill Garcia
Anthony L. Martin
Jill Garcia
Shelley L. Murray
3800 Howard Hughes Parkway
Suite 1500
Las Vegas, NV 89169
Telephone: [phone]
Attorneys for Defendants Eldorado Resorts
Corporation and Michael Marrs

4
5
6
7
8

10
11
Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

9

ORDER

12
13

IT IS SO ORDERED.

14
15
16

UNITED STATES MAGISTRATE JUDGE
February 10, 2017
DATED
.

17
18
19
20
21
22
23
24
25
26
27
28
3