Kraja v. Bellagio, LLC et al

Filing 21

ORDER Granting 20 Stipulation to Extend Time for Plaintiff to Respond to 17 Defendants' Motion to Partially Dismiss Plaintiff's Amended Complaint. Responses due by 12/17/2015. Replies due by 1/4/2016. Signed by Judge Andrew P. Gordon on 12/11/15. (Copies have been distributed pursuant to the NEF - PS)

JAMES P. KEMP, ESQ.
Nevada Bar No.: 6375
VICTORIA L. NEAL, ESQ.
Nevada Bar No.: 13382
KEMP & KEMP
7435 W. Azure Drive, Ste 110
Las Vegas, NV 89130
702-258-1183 ph./702-258-6983 fax
[e-mail]
[e-mail]
Attorneys for Plaintiff

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] Fax [phone]

KEMP & KEMP

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
***
)
ANDI KRAJA,
) Case No.: 2:15-cv-01983-APG-NJK
)
Plaintiff,
)
) STIPULATION AND ORDER TO
vs.
) EXTEND TIME FOR PLAINTIFF TO
) RESPOND TO
MOTION
BELLAGIO, LLC, a Nevada Corporation;
) TO PARTIALLY DISMISS
VINCENT ROTOLO, an individual; ROE
) AMENDED COMPLAINT AND FOR
) DEFENDANTS TO REPLY TO
Business Organizations I-X; and DOE
) RESPONSE
INDIVIDUALS I-X, Inclusive,
)
) [FIRST REQUEST]
Defendants.
)
)
It is hereby stipulated by and between the parties, through their respective counsel, that
Plaintiff, ANDI KRAJA

December 10, 2015, through and

including December 17, 2015, in which to file his Response to Defendant
Dismiss

Motion to Partially

(Dkt. # 11). This stipulation is submitted and based upon

the following:
1.

filed an Amended Complaint on Friday, November 6, 2015. (Dkt. # 11).
On November 23, 2015, Defendants filed a
Amended Complaint. (Dkt. #17).

2.

The parties have agreed to stipulate to this one-week extension for Plaintiff to
respond to

s Amended Complaint
nsel experiencing a family emergency.

3.

The parties additionally stipulate to a one-week extension, up to and including
Motion to
s Amended Complaint. This request for an extension of
time is due to the winter holidays occurring during the time frame in which
Defendants would otherwise be required to reply.

4.

These requests for extensions of time are made in good faith and not for purpose of

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] Fax [phone]

KEMP & KEMP

delay.
DATED this 10th day of December 2015.
/s/ Victoria L. Neal
JAMES P. KEMP, ESQ.
VICTORIA L. NEAL, ESQ.
KEMP & KEMP
7435 W. Azure Drive, Suite 110
Las Vegas, NV 89130
[phone] ph/ [phone] fax

/s/ Amy L. Baker
PATRICK H. HICKS, ESQ.
MONTGOMERY Y. PAEK, ESQ.
AMY L. BAKER, ESQ.
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169
[phone] ph/ [phone] fax

Attorneys for Plaintiff

Attorneys for Defendants
ORDER

IT IS SO ORDERED.

IT IS SO ORDERED:

______________________________________
____
_________________________
UNITED STATES MAGISTRATE JUDGE
STATES DISTRICT JUDGE
Dated: December 11, 2015.
Dated: _________________________________