My Left Foot Children's Therapy, LLC et al v. Certain Underwriter's at Lloyd's London Subscribing to Policy No. HAH15-0632

Filing 155

ORDER granting ECF No. 154 Stipulation. Plaintiffs' oppositions to the Motions (ECF Nos. 151 , 152 ) are due by September 18, 2020. Defendant's replies are due by October 2, 2020. Signed by Chief Judge Miranda M. Du on 6/25/2020. (Copies have been distributed pursuant to the NEF - AB)

Case 2:15-cv-01746-MMD-VCF Document 155 Filed 06/25/20 Page 1 of 4

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AKIN GUMP STRAUSS HAUER & FELD LLP
SHAWN HANSON (admitted pro hac vice)
580 California Street, Suite 1500
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
MARQUIS AURBACH COFFING
CRAIG R. ANDERSON, ESQ.
Nevada Bar No. 6882
10001 Park Run Drive
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiffs My Left Foot Children’s Therapy,
LLC, Jon Gottlieb, and Ann Marie Gottlieb

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UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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MY LEFT FOOT CHILDREN’S
THERAPY, LLC; JON GOTTLIEB AND
ANN MARIE GOTTLIEB,

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Plaintiffs,
v.
CERTAIN UNDERWRITERS AT
LLOYD’S LONDON SUBSCRIBING TO
POLICY NO. HAH15-0632,

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Defendant.

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Case No. 2:15-cv-01746- MMD- VCF
JOINT STIPULATION TO EXTEND
MOTION FOR SUMMARY JUDGMENT
DATES

Plaintiffs My Left Foot Children’s Therapy Services LLC, Jon Gottlieb, and Ann Marie

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Gottlieb (“Plaintiffs”) and Defendant Underwriters at Lloyd’s London Subscribing to Policy No.

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HAH15-0632 (“Defendant) (together with Plaintiffs, the “parties”) jointly submit this Stipulation to

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modify the briefing schedule on Defendant’s Motions for Partial Summary Judgment (Dkt. 151 and

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Dkt. 152):

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JOINT STIPULATION TO EXTEND MOTION FOR SUMMARY JUDGMENT DATES
CASE NO. 2:15-CV-01746- MMD-VCF

Case 2:15-cv-01746-MMD-VCF Document 155 Filed 06/25/20 Page 2 of 4

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WHEREAS, on June 9, 2020, Plaintiffs noticed two depositions: (i) a deposition pursuant to

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Federal Rule of Civil Procedure 30(b)(6) for Defendant to occur on July 17, 2020; and (ii) the 30(b)(1)

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deposition of Mr. Paul Bailey, to occur on July 16, 2020 (together, the “Depositions”);

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WHEREAS, after receiving the deposition notices, Mr. Barry Chasnoff, lead Counsel for

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Defendant, informed Plaintiffs’ counsel that he is scheduled to be on vacation and unavailable during

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the month of July;

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WHEREAS, Plaintiffs agreed to reschedule the Depositions for the first two weeks in August
to accommodate Mr. Chasnoff’s schedule;

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WHEREAS, on June 22, 2020, Defendant filed two motions for partial summary judgment

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(Dkt. 151 and Dkt. 152) (the “Motions”), which were accompanied by Declarations signed by Mr.

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Bailey and another witness, Carolyn Worster;

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WHEREAS, the current deadline for Plaintiffs to respond to the Motions is July 13, 2020,
which is before the planned Depositions;
WHEREAS, counsel for Defendant has agreed to set a briefing schedule on the Motions so that

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Plaintiffs may have the opportunity to depose Mr. Bailey, Ms. Worster, and/or a 30(b)(6) witness, as

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needed, before filing responses to the Motions;

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WHEREAS, Mr. Nicholas Gregory was previously the lead associate working on this case on
behalf of Plaintiffs, but is no longer employed at Akin Gump Strauss Hauer & Feld, LLP;
WHEREAS, Ms. Erin Brewer will now be the lead associate working on this case on behalf of

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Plaintiffs, and will be filing a motion for admission pro hac vice and notice of appearance in this

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matter this week. Ms. Brewer is an attorney licensed in the State of Texas, and has an application

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pending for admission to the California Bar. Ms. Brewer is scheduled to take the California Bar

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examination on September 9-10, 2020, and is scheduled to be on bar study leave from August 10-

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September 10, 2020;

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WHEREAS, Mr. Shawn Hanson, lead counsel for Plaintiffs is scheduled to be on vacation
during the latter half of the month of August;

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NOW, THEREFORE,

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The parties request that the Court enter an order setting a briefing schedule on the Motions as
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JOINT STIPULATION TO EXTEND MOTION FOR SUMMARY JUDGMENT DATES
CASE NO. 2:15-CV-01746- MMD-VCF

Case 2:15-cv-01746-MMD-VCF Document 155 Filed 06/25/20 Page 3 of 4

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follows:

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1. Plaintiff’s oppositions to the Motions shall be filed no later than September 18, 2020; and

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2. Defendant’s replies shall be filed no later than October 2, 2020.

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Respectfully Submitted,

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AKIN GUMP STRAUSS HAUER & FELD MARQUIS AURBACH COFFING
LLP

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By:
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/s/ Shawn Hanson
Shawn Hanson, Esq.
Admitted pro hac vice
580 California Street, Suite 1500
San Francisco, CA 94104
Attorney for Plaintiffs

By:

/s/ Craig R. Anderson
Craig R. Anderson, Esq.
Nevada Bar No. 6882
10001 Park Run Drive
Las Vegas, Nevada 89145
Attorney for Plaintiffs

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CHASNOFF MUNGIA VALKENAAR PEPPING & STRIBLING, LLP

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By:
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/s/ Barry A. Chasnoff
Barry A. Chasnoff
Admitted pro hac vice
1020 NE Loop 410, Suite 150
San Antonio, TX 78209
Attorney for Defendant

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IT IS SO ORDERED.

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_________________________
MIRANDA M. DU
UNITED STATES DISTRICT JUDGE
June 25
Date: ____________, 2020

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I, Shawn Hanson, attest that all other signatories listed above, and on whose behalf the filing is
submitted, concur in the filing’s content and have authorized the filing.
/s/ Shawn Hanson

Dated: June 25, 2020

Shawn Hanson

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JOINT STIPULATION TO EXTEND MOTION FOR SUMMARY JUDGMENT DATES
CASE NO. 2:15-CV-01746- MMD-VCF

Case 2:15-cv-01746-MMD-VCF Document 154 Filed 06/25/20 Page 4 of 4
155

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CERTIFICATE OF SERVICE
I am employed in the County of San Francisco, State of California. I am over the age of 18 and

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not a party to the within action; my business address is: 580 California Street, Suite 1500,

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San Francisco, California 94104. On June 25, 2020, I served the foregoing documents on the

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interested parties below, using the following means:

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All parties identified for Notice of Electronic Filing generated by the Court’s
CM/ECF system under the above-referenced case caption and number

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BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an

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agreement of the parties to accept service by e-mail or electronic transmission, I caused the document

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to be sent to the respective e-mail addresses of the parties as stated above.
I declare that I am employed in the office of a member of this Court at whose direction the
service was made. I declare under penalty of perjury that the foregoing is true and correct.
Executed on June 25, 2020, at San Francisco, California.

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Lorraine France-Gorn

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Lorraine France-Gorn

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CERTIFICATE OF SERVICE
CASE NO. 2:15-CV-01746- MMD-VCF