Sekkat v. Eldorado Resorts Corporation et al

Filing 68

ORDER Granting 67 Stipulation for Extension of Time (Third Request) re 64 MOTION for Summary Judgment. Responses due by 5/8/2017. Replies due by 6/7/2017. Signed by Judge Richard F. Boulware, II on 4/11/2017. (Copies have been distributed pursuant to the NEF - SLD)

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Case 2:15-cv-01029-RFB-PAL Document 67 Filed 04/10/17 Page 1 of 5 1 2 3 4 5 6 7 8 10 11 Wells Fargo Tower Suite 1500, 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 9 ANTHONY L. MARTIN, ESQ. Nevada Bar No. 8177 anthony.martin@ogletreedeakins.com JILL GARCIA, ESQ. Nevada Bar No. 7805 jill.garcia@ogletreedeakins.com BRIAN L. BRADFORD, ESQ. Nevada Bar No. 9518 brian.bradford@ogletreedeakins.com OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Wells Fargo Tower Suite 1500 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Fax: 702.369.6888 Attorneys for Defendants Eldorado Resorts Corporation and Michael Marrs 12 UNITED STATES DISTRICT COURT 13 FOR THE DISTRICT OF NEVADA 14 15 MOHAMMED ALI SEKKAT, 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-01029-RFB-PAL STIPULATION AND ORDER TO EXTEND TIME TO FILE DISPOSITIVE MOTIONS AND RESPONSES AND REPLIES THERETO (THIRD REQUEST) Defendants. Pursuant to LR IA 6-1, LR IA 6-2, LR 7-1 and LR 26-4, Plaintiff Mohammed Ali Sekkat 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 a response and reply to the previously filed 27 Dispositive Motion (ECF No. 64). Pursuant to the Stipulation and Order to Extend Time to File 28 Case 2:15-cv-01029-RFB-PAL Document 67 Filed 04/10/17 Page 2 of 5 1 Dispositive Motions, and Responses thereto (Second Request) (ECF No. 63), Defendants filed the 2 Dispositive Motion in this case on March 23, 2017 (ECF No. 64). The parties have completed all 3 discovery in this matter, and good cause exists for the proposed extension based upon the 4 following: 5 6 As the Court is aware, this case is one of over thirty 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. On February 10, 2017, the parties 10 agreed to a comprehensive briefing schedule for dispositive motions in the remaining groups of 11 Wells Fargo Tower Suite 1500, 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 9 cases. (ECF No. 63.) The current status of the comprehensive briefing schedule is as follows: 12 13 Group III(A)  Defendants shall file dispositive motions by February 27, 2017.  Plaintiffs shall file oppositions by March 29, 2017.  Defendants shall file replies by April 28, 2017. 14 15 16 17 Group III(B) 18  Defendants shall file dispositive motions by March 23, 2017. 19  Plaintiffs shall file oppositions by April 24, 2017.  Defendants shall file replies by May 24, 2017. 20 21 22 Group IV(A) 23  Defendants shall file dispositive motions by April 13, 2017. 24  Plaintiffs shall file oppositions by May 12, 2017. 25  Defendants shall file replies by June 13, 2017. 26 Group IV(B) 27 28  Defendants shall file dispositive motions by June 6, 2017. 2 Case 2:15-cv-01029-RFB-PAL Document 67 Filed 04/10/17 Page 3 of 5  Plaintiffs shall file oppositions by July 6, 2017. 2  Defendants shall file replies by August 7, 2017. 3 Group V 4  Defendants shall file dispositive motions by June 22, 2017.  Plaintiffs shall file oppositions by July 24, 2017.  Defendants shall file replies by August 23, 2017. 1 5 6 7 In compliance with that stipulation, Defendants filed Motions for Summary Judgment on 9 February 27, 2017, in Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv-01026-RFB-PAL 10 (ECF No. 60); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015-RFB-PAL (ECF No. 11 Wells Fargo Tower Suite 1500, 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 8 12 57); D. Parr v. Eldorado Resorts Corp., Case No.: 2:15-cv-01028-RFB-PAL (ECF No. 50); and Scheinberg v. Eldorado Resorts Corp., Case No.: 2:15-cv-01031-RFB-PAL (ECF No. 63). 13 14 Unilaterally and without notice to defense counsel, on the day before oppositions were due, 15 Plaintiffs filed a request for an extension to file oppositions to the Motions for Summary Judgment 16 on March 28, 2017, in the foregoing cases: Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv- 17 01026-RFB-PAL (ECF No. 63); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015- 18 RFB-PAL (ECF No. 60); D. Parr v. Eldorado Resorts Corp., Case No.: 2:15-cv-01028-RFB-PAL 19 (ECF No. 53); and Scheinberg v. Eldorado Resorts Corp., Case No.: 2:15-cv-01031-RFB-PAL 20 21 22 (ECF No. 66), seeking to extend the current filing date of March 29, 2017, to April 12, 2017. This request remains pending before the Court. Due to this delay, the entire comprehensive briefing 23 schedule has been impacted, causing overlapping and unreasonable deadlines. The delays will 24 make it difficult to comply with the current briefing schedules for the remaining matters. 25 26 Accordingly, the parties hereby stipulate to adjust the briefing schedule in the manner presented below in an effort to allow the parties to comply with the briefing schedule in a 27 reasonable manner as follows: 28 3 Case 2:15-cv-01029-RFB-PAL Document 67 Filed 04/10/17 Page 4 of 5 Group III(A) 1 2  Plaintiffs shall file oppositions by April 12, 2017. 3  Defendants shall file replies by May 12, 2017. 4 Group III(B) 5   6 7 Plaintiffs shall file oppositions by May 8, 2017. Defendants shall file replies by June 7, 2017. Group IV(A) 8  Defendants shall file dispositive motions by May 31, 2017. 10  Plaintiffs shall file oppositions by June 30, 2017. 11 Wells Fargo Tower Suite 1500, 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 9  Defendants shall file replies by July 31, 2017. 12 Group IV(B) 13  Defendants shall file dispositive motions by June 21, 2017. 15  Plaintiffs shall file oppositions by July 21, 2017. 16  Defendants shall file replies by August 21, 2017. 14 17 Group V 18  Defendants shall file dispositive motions by August 30, 2017.  Plaintiffs shall file oppositions by September 29, 2017.  Defendants shall file replies by October 30, 2017. 19 20 21 22 23 As relevant to this matter, the parties have agreed that the dispositive motion deadlines should be extended as follows: 24  Plaintiff shall file any response to Defendants’ dispositive motion no later than 25 May 8, 2017; 26  27 28 Defendants shall file their reply no later than June 7, 2017. ... 4 Case 2:15-cv-01029-RFB-PAL Document 67 Filed 04/10/17 Page 5 of 5 1 This stipulation is not brought for purposes of delay or any other improper purpose. 2 Dated this 10th day of April, 2017. 3 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 /s/ Anthony L. Martin Anthony L. Martin Jill Garcia Brian L. Bradford 3800 Howard Hughes Parkway Suite 1500 Las Vegas, NV 89169 4 5 6 7 8 Attorneys for Plaintiff Mohammed Ali Sekkat Attorneys for Defendants Eldorado Resorts Corporation and Michael Marrs 10 11 Wells Fargo Tower Suite 1500, 3800 Howard Hughes Parkway Las Vegas, NV 89169 Telephone: 702.369.6800 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. 9 ORDER 12 13 IT IS SO ORDERED. 14 15 16 UNITED STATES DISTRICT JUDGE April 11, 2017 DATED 17 18 19 20 21 22 23 24 25 26 27 28 5

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