Kwist v. Harrah's Las Vegas, LLC

Filing 10

ORDER Granting 9 Stipulation to Extend Deadline to File Amended Complaint and Defendant to File Responsive Pleading to Amended Complaint. Signed by Magistrate Judge Peggy A. Leen on 4/20/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:16-cv-00095-JCM-PAL Document 9 Filed 04/18/16 Page 1 of 3

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Deverie Christensen, Bar No. 6596
[e-mail]
JACKSON LEWIS P.C.
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
Harrah’s Las Vegas, LLC

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA

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KARLA K. KWIST, an individual;
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Case No.: 2:16-cv-00095-JCM-PAL
Plaintiff,

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v.
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HARRAH’S LAS VEGAS, LLC, a Nevada
limited liability company; DOES 1 through
10 inclusive; ROE
CORPORATIONS/ENTITIES 1 through
10 inclusive,

STIPULATION AND ORDER TO EXTEND
DEADLINE FOR PLAINTIFF TO FILE
AMENDED COMPLAINT AND DEFENDANT
TO FILE RESPONSIVE PLEADING TO
AMENDED COMPLAINT (Second Request)

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Defendants.
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JACKSON LEWIS P.C.
LAS VEGAS

Defendant Harrah’s Las Vegas, LLC ("Defendant"), by and through its counsel of record,
Jackson Lewis P.C., and Plaintiff Karla K. Kwist ("Plaintiff"), by and through her counsel of
record, The Thater Law Group, P.C., hereby stipulate and agree to extend the time for Plaintiff to
file an Amended Complaint for one week, up to and including April 25, 2016, and for Defendant
to thereafter file a responsive pleading to Plaintiff's Amended Complaint pursuant to applicable
Court Rules.
The parties collectively request this extension for the following reasons:


On June 5, 2014, Plaintiff dual-filed a charge of discrimination with the Nevada Equal
Rights Commission (“NERC”) and U.S. Equal Employment Opportunity Commission
(“EEOC”). On August 31, 2015, the NERC closed its case. On October 14, 2015, the

Case 2:16-cv-00095-JCM-PAL Document 9 Filed 04/18/16 Page 2 of 3

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EEOC issued a right to sue notice, and on January 15, 2016, Plaintiff filed the instant

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lawsuit (Case 2:16-cv-00095-JCM-PAL).


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On October 29, 2015, Plaintiff dual-filed a new charge of discrimination with the

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NERC and EEOC, and requested the immediate issuance of a right to sue notice. On

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February 4, 2016, the NERC closed its case due to Plaintiff’s request for an immediate

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right to sue notice from the EEOC.


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On February 26, 2016, the Court granted a proposed stipulation of the parties

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extending the time for Defendant to file a response to Plaintiff’s original complaint, up

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to and including April 18, 2016, in anticipation of the EEOC issuing a right to sue

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notice to Plaintiff within the next 30-45 calendar days; thereafter, Plaintiff planned to

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file an amended complaint to include all of her claims against Defendant in one case.


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The EEOC has now issued Plaintiff a right to sue notice, and Plaintiff needs a short
time to prepare an amended complaint.

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

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Plaintiff will amend her complaint to include all of her claims against Defendant,
specifically those in her new charge.

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

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Defendant’s undersigned counsel has been authorized by Defendant to accept service
of Plaintiff’s amended complaint (once filed).

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

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Thus, the parties are requesting a one-week extension of the time for Plaintiff to

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prepare and file her amended complaint. Thereafter, Defendant’s counsel will accept

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service of the amended complaint and Defendant will file a response to the amended

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complaint pursuant to Court Rules.

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JACKSON LEWIS P.C.
LAS VEGAS

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Case 2:16-cv-00095-JCM-PAL Document 9 Filed 04/18/16 Page 3 of 3

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This stipulation and order is sought in good faith and not for the purpose of delay. This is
the second request for an extension of time.
Dated this 18th day of April, 2016.

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THE THATER LAW GROUP, P.C.

JACKSON LEWIS P.C.

/s/ M. Lani Esteban-Trinidad
M. Lani Esteban-Trinidad, Esq., Bar #6967
6390 W. Cheyenne Ave., Ste. A
Las Vegas, Nevada 89108
Attorney for Plaintiff

/s/ Deverie J. Christensen
Deverie J. Christensen, Bar No. 6596
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Attorneys for Defendant

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ORDER

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IT IS SO ORDERED

April 20 , 2016.

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U.S. District/Magistrate Judge

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4827-3886-8272, v. 1

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JACKSON LEWIS P.C.
LAS VEGAS

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