Landry's Inc. et al v. Brian Sandoval, et al

Filing 81

ORDER re 80 Stipulation and Order To Extend Time for Plaintiffs To File Their Opposition To Intervenor Nevada State Federation Of Labor, AFL-CIO's Motion to Dismiss Second Amended Complaint (First Request). Responses due by 9/20/2016. Signed by Chief Judge Gloria M. Navarro on 8/24/2016. (Copies have been distributed pursuant to the NEF - DL)

Case 2:15-cv-01160-GMN-PAL Document 80 Filed 08/19/16 Page 1 of 2

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Elayna J. Youchah, Bar # 5837
[e-mail]
Phillip C. Thompson, Bar # 12114
[e-mail]
JACKSON LEWIS P.C.
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
René E. Thorne, LA Bar No.22875
Admitted Pro Hac Vice
[e-mail]
JACKSON LEWIS P.C.
650 Poydras Street, Suite 1900
New Orleans, Louisiana 70130
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs Landry’s Inc.,
Claim Jumper Acquisition Company, LLC
And Bubba Gump Shrimp Co. Restaurants, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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LANDRY’S, INC., a Delaware corporation;
CLAIM JUMPER ACQUISITION
COMPANY, LLC, a Nevada limited liability
company; BUBBA GUMP SHRIMP CO.
RESTAURANTS, INC., a Delaware
corporation,

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Plaintiffs,
v.
BRIAN SANDOVAL, in his official capacity as
Governor of the State of Nevada; SHANNON
CHAMBERS, in her official capacity as Labor
Commissioner of the State of Nevada, AMY L.
PARKS, in her official capacity as Acting
Insurance Commissioner of the State of Nevada,

Case No. 2:15-cv-01160-GMN-PAL

STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFFS
TO FILE THEIR OPPOSITION TO
INTERVENOR NEVADA STATE
FEDERATION OF LABOR, AFLCIO’S MOTION TO DISMISS
SECOND AMENDED COMPLAINT
(First Request)

Defendants.
Plaintiffs Landry's, Inc., Bubba Gump Restaurants, Inc., and Claim Jumper Acquisition

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Company, LLC (collectively, "Plaintiffs"), by and through their counsel of record, Jackson Lewis
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JACKSON LEWIS P.C.
LAS VEGAS

P.C., and Intervenor Nevada State Federation of Labor, AFL-CIO (“Intervenor”), by and through

Case 2:15-cv-01160-GMN-PAL Document 80 Filed 08/19/16 Page 2 of 2

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its counsel of record, McCracken , Stemerman & Holsberry, hereby stipulate and agree to extend

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the time for the Plaintiffs to file their opposition to Intervenor's Motion to Dismiss Second

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Amended Complaint ("Motion to Dismiss").

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This extension is necessary because the Motion to Dismiss raises numerous questions of

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federal and state statutory and constitutional law. The nature of the claims and parties in this case

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and the subjects underlying the Motion to Dismiss are such that Plaintiffs require substantially more

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time to brief them than a typical motion under Fed. R. Civ. P. 12(b)(6).

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Accordingly, the parties stipulate and agree that Plaintiffs shall have a brief, two-week

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extension through and including September 20, 2016, to file their Opposition to the Motion to

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Dismiss.
This stipulation and order is sought in good faith and not for the purpose of delay. No prior
request for any extension of time has been made.
Dated this 19th day of August, 2016.
McCRACKEN, STEMERMAN &
HOLSBERRY

JACKSON LEWIS P.C.

/s/ Richard McCracken
Richard McCracken, Bar # 2748
1630 S. Commerce Street, Suite A-1
Las Vegas, Nevada 89102

/s/ Phillip C. Thompson
Elayna J. Youchah, Bar # 5837
Phillip C. Thompson, Bar # 12114
3800 Howard Hughes Parkway, Ste. 600
Las Vegas, Nevada 89169
Attorneys for Plaintiffs

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Attorneys for Intervenor
Nevada State Federation of Labor, AFL-CIO

ORDER
IT IS SO ORDERED.
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DATED this ___ day of August, 2016.

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U.S. District Judge

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JACKSON LEWIS P.C.
LAS VEGAS

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