Kraja v. Bellagio, LLC et al

Filing 25

ORDER Granting 24 Stipulation to Extend Time for Defendants to File Reply in Support of Motion for Partially Dismiss Plaintiff's Amended Complaint. Reply is due by 1/14/16. Signed by Judge Andrew P. Gordon on 12/30/15. (Copies have been distributed pursuant to the NEF - PS)

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1 2 3 4 5 6 PATRICK H. HICKS, ESQ., Bar # 004632 MONTGOMERY Y. PAEK, ESQ., Bar # 10176 AMY L. BAKER, ESQ., Bar # 11907 LITTLER MENDELSON, P.C. 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89169-5937 Telephone: 702.862.8800 Fax No.: 702.862.8811 Attorneys for Defendants BELLAGIO, LLC and VINCENT ROTOLO 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 ANDI KRAJA, Case No. 2:15-cv-01983-APG-NJK 12 Plaintiff, 13 vs. 14 15 16 BELLAGIO, LLC, a Nevada Corporation; VINCENT ROTOLO, an individual; ROE Business Organizations I-X; and DOE INDIVIDUALS I-X, Inclusive, Defendants. 17 [PROPOSED] STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE REPLY IN SUPPORT OF MOTION TO PARTIALLY DISMISS PLAINTIFF'S AMENDED COMPLAINT [SECOND REQUEST] 18 19 Plaintiff ANDI KRAJA (hereinafter “Plaintiff”) and Defendants BELLAGIO, LLC and 20 VINCENT ROTOLO (hereinafter “Defendants”), by and through their counsel of record, hereby 21 stipulate and agree to extend the time for Defendants to file a Reply in Support of Defendant’s 22 Motion to Partially Dismiss Plaintiff's Amended Complaint from the current deadline of January 4, 23 2016 (Doc. 21) up to and including January 14, 2016. This stipulation is submitted as this matter is 24 scheduled for an Early Neutral Evaluation conference on January 7, 2016 (Doc. 14) and the parties 25 desire to focus their resources toward the upcoming ENE. 26 ... 27 ... 28 ... LITTLE R MENDELSON , P.C. ATTORNEYS AT LAW 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89169-5937 702.862.8800 1 This is the second request for an extension of time for Defendants to file their Reply. The 2 parties agree and represent to the Court that this request is made in good faith and not for the 3 purpose of delay. 4 Dated: December 30, 2015 Dated: December 30, 2015 5 Respectfully submitted, Respectfully submitted, 6 7 8 9 10 11 /s/ Victoria L. Neal /s/ Amy L. Baker JAMES P. KEMP, ESQ. PATRICK H. HICKS, ESQ. VICTORIA L. NEAL, ESQ. MONTGOMERY Y. PAEK, ESQ. KEMP & KEMP, ATTORNEYS AT LAW AMY L. BAKER, ESQ. LITTLER MENDELSON, P.C. Attorneys for Plaintiff ANDI KRAJA 12 Attorneys for Defendants BELLAGIO, LLC and VINCENT ROTOLO ORDER 13 IT IS SO ORDERED. 14 December 30 Dated: _____________________, 2015. 15 16 17 _______________________________________ __________________________ UNITED STATES DISTRICT C COURT JUDGE 18 19 20 Firmwide:137786079.1 060736.1097 21 22 23 24 25 26 27 28 LITTLE R MENDELSON , P.C. ATTORNEYS AT LAW 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89169-5937 702.862.8800 2.

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