Kraja v. Bellagio, LLC et al
Filing
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ORDER Granting 233 Stipulation to Extend Time for Plaintiff to Obtain an Expert and Submit an Expert Report. Due by 11/21/2019. Signed by Judge Andrew P. Gordon on 11/6/2019. (Copies have been distributed pursuant to the NEF - ADR)
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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
jp@kemp-attorneys.com
vneal@kemp-attorneys.com
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Attorneys for Plaintiff
Andi Kraja
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. (702) 258-1183 ♦ Fax (702) 258-6983
KEMP & KEMP
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ANDI KRAJA
Case No.: 2:15-cv-01983-APG-NJK
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Plaintiff,
vs.
STIPULATION TO EXTEND TIME
FOR PLAINTIFF TO OBTAIN AN
EXPERT AND SUBMIT AN EXPERT
REPORT AND ORDER
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BELLAGIO, LLC, a Nevada Corporation;
VINCENT DEFENDANT ROTOLO, an
Individual,
Defendants.
(FIRST REQUEST)
Hearing Date: January 3, 2020
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On September 26, 2019, the Court ordered the parties meet and confer regarding the
scheduling of an evidentiary hearing, including a schedule for possible discovery. The parties met
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and conferred and on October 8, 2019, submitted a Joint Status Report/Stipulation For Proposed
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Schedule which was approved by the Court on October 9, 2019. ECF No. 232. The Stipulation
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reads in part “Kraja shall have until November 8, 2019 to retain and disclose an expert report
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regarding the Visual Evidence. Kraja reserves the right to seek additional time to retain and disclose
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an expert report, should the need for such an extension arise.” Id. at 2:4-6. An expert (out of area)
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has been located and a meeting scheduled for November 11, 2019. It is unknown at this time how
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long it will take for the expert to draft a report. The parties stipulate that Plaintiff may have up to and
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including November 21, 2019 in which to submit an expert report, but may request additional time
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should the need for such an extension arise.
Dated this 6th day of November, 2019.
KEMP & KEMP
PISANELLI BICE PLLC
By: /s/ Victoria L. Neal, Esq.
James P. Kemp, Esq., Bar No. 6375
Victoria L. Neal, Esq., Bar No. 13382
7435 W. Azure Drive, Suite 110
Las Vegas, Nevada 89130
By: /s/ Robert A. Ryan, Esq.
Todd L. Bice, Esq., Bar No. 4534
Robert A. Ryan, Esq., Bar No. 12084
400 South 7th Street, Suite 300
Las Vegas, Nevada 89101
Attorneys for Plaintiff, Andi Kraja
Attorneys for Defendant, Bellagio LLC
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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. (702) 258-1183 ♦ Fax (702) 258-6983
KEMP & KEMP
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IT IS SO ORDERED:
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________________________________
DISTRICT COURT JUDGE
UNITED STATES DISTRICT JUDGE
Dated: November 6, 2019.
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DATED: ___________________
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