Parr v. Eldorado Resorts Corporation et al

Filing 57

ORDER Granting 56 Stipulation for Extension of Time (Third Request). Motions due by 5/8/2017. Replies due by 6/7/2017. Signed by Judge Richard F. Boulware, II on 4/11/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:15-cv-01030-RFB-PAL Document 56 Filed 04/10/17 Page 1 of 5

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Attorneys for Defendants Eldorado Resorts Corporation,
and Michael Marrs

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

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

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ANTHONY L. MARTIN, ESQ.
Nevada Bar No. 8177
[e-mail]
JILL GARCIA, ESQ.
Nevada Bar No. 7805
[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]

UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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MARCELLA PARR,
Case No. 2:15-cv-01030-RFB-PAL

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Plaintiff,
vs.
ELDORADO RESORTS CORPORATION, a
Florida Corporation; MICHAEL MARRS;
BRUCE POLANSKY; KRISTEN BECK;
DOMINIC TALAGANI; JAMES GRIMES;
and DOES 1-50, inclusive,

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 and LR 26-4, Plaintiff Marcella Parr and Defendants
Eldorado Resorts Corporation ("Eldorado") and Michael Marrs (“Marrs”) (collectively

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

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request for extension of time for the parties to file a response and reply to the previously filed

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Dispositive Motion (ECF No. 53). Pursuant to the Stipulation and Order to Extend Time to File

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Dispositive Motions, and Responses thereto (Second Request) (ECF No. 52.), Defendants filed the

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Case 2:15-cv-01030-RFB-PAL Document 56 Filed 04/10/17 Page 2 of 5

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Dispositive Motion in this case on March 23, 2017 (ECF No. 53). The parties have completed all

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discovery in this matter, and good cause exists for the proposed extension based upon the

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following:

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As the Court is aware, this case is one of over thirty related lawsuits sitting before this

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Court. Recognizing the complexity of litigating these lawsuits simultaneously, the parties agreed
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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 9, 2017, the parties

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agreed to a comprehensive briefing schedule for dispositive motions in the remaining groups of

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

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

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cases. (ECF No. 52.) The current status of the comprehensive briefing schedule is as follows:
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.

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Group III(B)

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

Defendants shall file dispositive motions by March 23, 2017.

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

Plaintiffs shall file oppositions by April 24, 2017.



Defendants shall file replies by May 24, 2017.

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Group IV(A)

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

Defendants shall file dispositive motions by April 13, 2017.

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

Plaintiffs shall file oppositions by May 12, 2017.

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

Defendants shall file replies by June 13, 2017.

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Group IV(B)


Defendants shall file dispositive motions by June 6, 2017.



Plaintiffs shall file oppositions by July 6, 2017.

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Case 2:15-cv-01030-RFB-PAL Document 56 Filed 04/10/17 Page 3 of 5

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

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Group V

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

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.

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Defendants shall file replies by August 7, 2017.

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In compliance with that stipulation, Defendants filed Motions for Summary Judgment on

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February 27, 2017, in Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv-01026-RFB-PAL

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(ECF No. 60); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015-RFB-PAL (ECF No.

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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).

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

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

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Unilaterally and without notice to defense counsel, on the day before oppositions were due,
Plaintiffs filed a request for an extension to file oppositions to the Motions for Summary Judgment

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on March 28, 2017, in the foregoing cases: Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv-

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01026-RFB-PAL (ECF No. 63); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015-

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RFB-PAL (ECF No. 60); D. Parr v. Eldorado Resorts Corp., Case No.: 2:15-cv-01028-RFB-PAL

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(ECF No. 53); and Scheinberg v. Eldorado Resorts Corp., Case No.: 2:15-cv-01031-RFB-PAL

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(ECF No. 66), seeking to extend the current filing date of March 29, 2017, to April 12, 2017. This
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request remains pending before the Court. Due to this delay, the entire comprehensive briefing

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schedule has been impacted, causing overlapping and unreasonable deadlines. The delays will

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make it difficult to comply with the current briefing schedules for the remaining matters.

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...

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...

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...

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...
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Case 2:15-cv-01030-RFB-PAL Document 56 Filed 04/10/17 Page 4 of 5

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Accordingly, the parties hereby stipulate to adjust the briefing schedule in the manner

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presented below in an effort to allow the parties to comply with the briefing schedule in a

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reasonable manner as follows:

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Group III(A)

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

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Plaintiffs shall file oppositions by April 12, 2017.



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Defendants shall file replies by May 12, 2017.

Group III(B)

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

Plaintiffs shall file oppositions by May 8, 2017.

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

Defendants shall file replies by June 7, 2017.

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Group IV(A)

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

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

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

Defendants shall file dispositive motions by May 31, 2017.

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

Plaintiffs shall file oppositions by June 30, 2017.

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

Defendants shall file replies by July 31, 2017.

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Group IV(B)

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


Plaintiffs shall file oppositions by July 21, 2017.



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Defendants shall file dispositive motions by June 21, 2017.

Defendants shall file replies by August 21, 2017.

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Group V

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

Defendants shall file dispositive motions by August 30, 2017.

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

Plaintiffs shall file oppositions by September 29, 2017.



Defendants shall file replies by October 30, 2017.

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As relevant to this matter, the parties have agreed that the dispositive motion deadlines

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should be extended as follows:
...

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Case 2:15-cv-01030-RFB-PAL Document 56 Filed 04/10/17 Page 5 of 5

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

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Plaintiff shall file any response to Defendants’ dispositive motion no later than
May 8, 2017;



Defendants shall file their reply no later than June 7, 2017.

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This stipulation is not brought for purposes of delay or any other improper purpose.
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Dated this 10th day of April, 2017.
WATKINS & LETOFSKY, LLP

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

/s/ Daniel R. Watkins
Daniel R. Watkins
Brian S. Letofsky
8215 South Eastern Ave
Suite 265
Las Vegas, NV 89123
Telephone: [phone]
Attorneys for Plaintiff Marcella Parr

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

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

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

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ORDER

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IT IS SO ORDERED.

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UNITED STATES DISCTRICT JUDGE
DATED:

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April 11, 2017