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

Filing 246

ORDER - The hearing on the Pending Motions is hereby rescheduled from October 14, 2021, to December 8, 2021 at 1:00pm before Magistrate Judge Cam Ferenbach. The parties must submit a separate stipulation to Chief Judge Du on the briefing for the Motion for Partial Summary Judgment. Signed by Magistrate Judge Cam Ferenbach on 10/7/2021. (Copies have been distributed pursuant to the NEF - SC)

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AKIN GUMP STRAUSS HAUER & FELD LLP
SHAWN HANSON (admitted pro hac vice)
ERIN BREWER (admitted pro hac vice)
580 California Street, Suite 1500
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[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,
Defendant.

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Case No. 2:15-cv-01746-MMD-VCF
JOINT STIPULATION TO MODIFY
HEARING DATE AND BRIEFING
SCHEDULE

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: (1) the October 14, 2021 hearing date set by ECF No. 241 on the following motions: ECF

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Nos. 219, 220, 221, 222, 231, 232, and 233 (the “Pending Motions”), and (2) the time to file a

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JOINT STIPULATION TO MODIFY HEARING DATE AND BRIEFING SCHEDULE
CASE NO. 2:15-CV-01746- MMD-VCF

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response in opposition to Plaintiffs’ Motion for Partial Summary Judgment (ECF No. 240), which was

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filed September 21, 2021 (the “MPSJ”). In support thereof, the parties state as follows:

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WHEREAS, over the past few months, the parties filed several motions, including the Pending
Motions and MPSJ;

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WHEREAS, the Pending Motions have been fully briefed;

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WHEREAS, under Local Rule 7-2, Defendant’s deadline to file a response to the MPSJ is

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October 12, 2021, and Plaintiffs’ deadline to file a reply in support of the MPSJ is 14 days after service

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of the response;

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WHEREAS, on September 29, 2021, the Court entered an order setting a hearing date on the
Pending Motions (see ECF No. 241);

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WHEREAS, the hearing is currently set for October 14, 2021;

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WHEREAS, the availability of both parties’ counsel has been affected by personal and medical

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issues since September 2021 (see ECF No. 243);

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WHEREAS, Plaintiffs have multiple conflicts with the October 14 hearing date, including: (1)

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lead counsel has a longstanding personal appointment that conflicts with the October 14 date, and (2)

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another of Plaintiffs’ counsel will be out of the country October 11-21 for a vacation and family

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engagement that had been scheduled many months prior;

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WHEREAS, the briefing schedule on Plaintiffs’ MPSJ also poses additional scheduling
conflicts with the hearing date;
WHEREAS, Plaintiffs have conferred with counsel for Defendant regarding the above, and

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requested that: (1) the hearing be moved to the week of November 1, 2021, (2) the deadline for

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Defendant to file its response to Plaintiffs’ MPSJ be moved to October 26, 2021, and (3) the reply in

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support of Plaintiffs’ MPSJ be moved to November 16, 2021;

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WHEREAS, there is good cause to postpone the hearing until the week of November 1, 2021

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and to extend the MPSJ briefing deadlines, and this stipulation is made in good faith, and not for some

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impermissible purpose such as to harass, delay, or prejudice;

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WHEREAS, this is the parties’ first request to postpone the hearing and this briefing;

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JOINT STIPULATION TO MODIFY HEARING DATE AND BRIEFING SCHEDULE
CASE NO. 2:15-CV-01746- MMD-VCF

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NOW, THEREFORE, the parties request that the Court enter an order rescheduling the hearing

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on the Pending Motions to the week of November 1, 2021 (or to the next available date on the Court’s

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docket thereafter), and extending the briefing schedule for Plaintiffs’ MPSJ, so that Defendant’s

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Opposition is due on October 26, 2021, and Plaintiffs’ Reply due November 16, 2021.

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Dated: October 7, 2021

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Respectfully Submitted,

Respectfully Submitted,

AKIN GUMP STRAUSS HAUER &
FELD LLP

MARQUIS AURBACH COFFING

By:

By:

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/s/ Shawn Hanson
Shawn Hanson
Admitted pro hac vice
580 California Street, Suite 1500
San Francisco, CA 94104
Attorneys for Plaintiffs

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

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CHASNOFF MUNGIA VALKENAAR
PEPPING & STRIBLING, LLP

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By: /s/ Adam Kiehne
Adam Kiehne
Admitted pro hac vice
1020 NE Loop 410, Suite 150
San Antonio, TX 78209
Attorneys for Defendant

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ORDER
The hearing on the Pending Motions is hereby rescheduled from October 14, 2021, to
December 8, 2021 at 1:00 PM.
The briefing schedule for Plaintiffs’ MPSJ is as follows: Defendant’s Opposition due on
October 26, 2021, and Plaintiffs’ Reply due on November 16, 2021.
IT IS HEREBY ORDERED that the parties
IT IS SO ORDERED:
must submit a separate stipulation to
Chief Judge Du on the briefing for the
_____________________________________
Motion for Partial Summary Judgment.
UNITED STATES MAGISTRATE JUDGE
10-7-2021
DATED: _________________

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JOINT STIPULATION TO MODIFY HEARING DATE AND BRIEFING SCHEDULE
CASE NO. 2:15-CV-01746- MMD-VCF

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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.

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/s/ Shawn Hanson

Dated: October 7, 2021

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Shawn Hanson

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JOINT STIPULATION TO MODIFY HEARING DATE AND BRIEFING SCHEDULE
CASE NO. 2:15-CV-01746- MMD-VCF

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CERTIFICATE OF SERVICE
My Left Foot Children’s Therapy, LLC, et al. v.
Certain Underwriters at Lloyd’s London Subscribing to Policy No. HAH15-0632
U. S. District Court of Nevada Case No. 2:15-cv-01746- MMD-VCF
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, San

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Francisco, California 94104. My email address is: [e-mail]. On October 7, 2021,

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I served the foregoing documents described as:

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1. JOINT STIPULATION TO MODIFY HEARING DATE AND BRIEFING
SCHEDULE
on the 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
BY ELECTRONIC MAIL OR ELECTRONIC TRANSMISSION: Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents
to be sent to the respective e-mail addresses of the parties as stated above. I did not receive, within a
reasonable time after the transmission, any electronic message or other indication that the transmission
was unsuccessful.
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 October 7, 2021, at San Francisco, California.

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/s/ Lorraine France-Gorn
Lorraine France-Gorn

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CERTIFICATE OF SERVICE
Case No. 2:15-cv-01746- MMD-VCF