Amsel v. Eliades et al

Filing 150

ORDER Granting 149 Stipulation for Extension of Time (Second Request) re 143 MOTION for Summary Judgment. Plaintiffs' Responses due by 10/10/2017. Signed by Judge Richard F. Boulware, II on 9/18/2017. (Copies have been distributed pursuant to the NEF - SLD)

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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, Suite 110
Las Vegas, Nevada 89130
Ph. [phone] / Fax [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs,
Amsel, Rivera, and Maltman

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
***

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JONAH AMSEL; JULIO RIVERA; and,
EDUARDO MALTMAN,

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

KEMP & KEMP

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Plaintiffs,

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vs.

DOUGLAS G. GERRARD; DOLORES
ELIADES; and, ARISTOTELIS ELIADES;
DOES I through X; and, ROES I through X’
inclusive,
Defendants.

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Case No.: 2:16-cv-00999-RFB-GWF

[PROPOSED] STIPULATION AND
ORDER FOR EXTENSION OF TIME
TO FOR PLAINTIFF’S TO RESPOND
TO DEFENDANT ARISTOTELIS
ELIADES’ MOTION FOR SUMMARY
JUDGMENT
[SECOND REQUEST]

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Pursuant to Local Rules IA 6-1, LR IA 6-2, and LR 7-1, Plaintiffs JONAH AMSEL,

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JULIO RIVERA, and EDUARDO MALTMAN (“Plaintiffs”), by and through their undersigned

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counsel, James P. Kemp, Esq. and Victoria L. Neal, Esq., of the law firm of Kemp & Kemp, and

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Defendant ARISTOTELIS ELIADES (“Defendant”), by and through his undersigned counsel,

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Gregory A. Miles, Esq., of the law firm of Royal and Miles, hereby stipulate, subject to approval
by the Court, to extend the time for Plaintiffs to respond to Defendant’s Motion For Summary

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Judgment.
This is the second request for an extension of time for Plaintiffs to respond to Defendant

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Aristotelis Eliades’ Motion for Summary Judgement. This quest is sought in good faith and not

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for purposes of undue delay.

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I.

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RELEVANT FACTS
Discovery in this matter closed June 16, 2017. ECF No. 135. Because Plaintiffs’

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deposition were taken late in the process, including one on June 15, 2017, and the need for the

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transcripts to be reviewed and obtained, the parties stipulated to, and the court granted, an

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extension of the dispositive motion deadline to September 5, 2017. ECF No. 141.

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1, 2017, Defendant Aristotelis Eliades’ filed his motion for summary judgement. Plaintiffs’

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response deadline is August 22, 2017. ECF No. 143. Counsel for Plaintiffs and Defendant

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On August

Aristotelis Eliades stipulated to an extension of Plaintiffs’ deadline to respond up to and

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

KEMP & KEMP

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including September 19, 2017, which the Court granted. ECF No. 146. In the interim, Plaintiffs
and the Defendants Dolores Eliades and Douglas Gerrard stipulated to extend the dispositive

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motion deadline up to and including September 19, 2017, which the Court granted. ECF No.

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148. When the parties stipulated to extend the dispositive motion deadline for Defendants

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Dolores Eliades and Douglas Gerrard, Plaintiffs reached out to Defendant Aristotelis Eliades to

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request extending Plaintiffs responsive deadline again to account for the new conflict. Id. This
stipulation follows as a result and Plaintiffs and Defendant Aristotelis Eliades hereby stipulate,

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subject to approval by the Court, that Plaintiffs deadline to respond be extended up to and
including October 10, 2017.
II.

REASON FOR EXTENSION

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The extension is necessary primarily because of the extension of the dispositive motion

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deadline for the other two Defendants in this matter, but also includes Plaintiffs’ counsels’ heavy

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workload through September 15, 2017.

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Therefore, the parties agree that an extension of time is appropriate and stipulate that

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Plaintiffs have up to and including October 10, 2017, subject to approval by the Court, in which

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to respond to Defendant Aristotelis Eliades’ motion for summary judgment.

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Respectfully submitted,
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Dated this 15th day of September, 2017.

Dated this 15th day of September, 2017.

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/s/
Gregory A. Miles
Gregory A. Miles, Esq.
ROYAL & MILES
1522 W. Warm Springs Road
Henderson, NV 89104
Phone: [phone]
Facsimile: 702. 531.6777

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

KEMP & KEMP

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Attorney for Defendant,
Aristotelis Eliades

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/s/ Victoria L. Neal
JAMES P. KEMP, ESQ.
Nevada Bar No.: 6375
VICTORIA L. NEAL, ESQ.
Nevada Bar No.: 13382
KEMP & KEMP
7435 W. Azure Drive, Suite 110
Las Vegas, Nevada 89130
Phone: [phone]
Facsimile: 702.258. 6983
Attorneys for Plaintiffs,
Amsel, Rivera, and Maltman

ORDER

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IT IS SO ORDERED:
September 18, 2017.
Dated: ___________________

________________________________________
UNITED STATES DISTRICT COURT JUDGE
HONORABLE RICHARD F. BOULWARE

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CERTIFICATE OF SERVICE
This is to certify on the date indicated below the within and foregoing document was
served via the court’s CM/ECF system to the following persons or parties:

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All Parties Registered
Through the CM/ECF system.

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Dated this 15th day of September, 2017.

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/s/ Victoria L. Neal
VICTORIA L. NEAL, ESQ.

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

KEMP & KEMP

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