Vilela et al v. Valley Health System LLC et al

Filing 23

ORDER Granting 18 Stipulation re 12 MOTION to Dismiss . The due date for the Opposition is retroactively extended to 10/4/16. Signed by Judge Richard F. Boulware, II on 10/10/16. (Copies have been distributed pursuant to the NEF - ADR)

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CASEY D. GISH, Esq.
Nevada Bar No. 6657
THE LAW OFFICE OF CASEY D. GISH
5940 S. Rainbow Blvd.
Las Vegas, NV 89118
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiffs

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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THE LAW OFFICE OF CASEY D. GISH
5940 S. Rainbow Blvd.
Las Vegas, Nevada 89118
Phone [phone]

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AMY VILELA, an individual;
JOZETTE FIGUEREDO, an individual;
AMY VILELA, as Special Administrator of the
Estate of SHALYNNE RAMOS,
Plaintiffs,

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Case No.: 2:16-cv-01503
STIPULATION AND PROPOSED ORDER
TO EXTEND DUE DATE FOR
PLAINTIFFS’ OPPOSITION TO
DEFENDANT TANYA NETZ’ MOTION
TO DISMISS

vs.
FIRST REQUEST

VALLEY HEALTH SYSTEM, LLC, d/b/a
CENTENNIAL HILLS HOSPITAL
MEDICAL CENTER, a Delaware Limited
Liability Company;
UNIVERSAL HEALTH SERVICES, INC., a
Delaware corporation; VALLEY HOSPITAL
MEDICAL CENTER, INC., a Nevada
Corporation; EMCARE, INC., a Deleware
Corporation; Tanya Netz PAC; Jill Mcatee, RN;
DOE Defendants I through X, inclusive; ROE
NURSES I through XX, inclusive; ZOE
HOSPITALS or OTHER MEDICAL
FACILITIES I through X; and ROE
CORPORATIONS I through X, inclusive.
Defendants.

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Plaintiffs, by and through their attorney of record, Casey D. Gish, Esq. of The Law Office

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of Casey D. Gish and Defendant, TANYA NETZ, PAC, by and through her attorney of record,

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Todd Weiss, Esq. of John H. Cotton and Associates, hereby stipulate as follows:

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(1) The due date for Plaintiffs’ Opposition to Defendant NETZ’s Motion to Dismiss (ECF
12) was October 3, 2016.
(2) The parties agree that the due date for the Opposition should be extended to October 4,
2016.
(3) Counsel for Plaintiffs moved his office location beginning September 28, 2016. The
move continued through October 1, 2016.

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(4) Counsel for Plaintiff has had intermittent computer problems while getting his new

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office location set-up. These problems resulted in the inability of Plaintiffs’ Counsel

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to file Plaintiffs’ Opposition to Defendant NETZ’s Motion to Dismiss until 5:37 a.m.

THE LAW OFFICE OF CASEY D. GISH
5940 S. Rainbow Blvd.
Las Vegas, Nevada 89118
Phone [phone]

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on October 4, 2016, which was 5 hours and 37 minutes late.
(5) Counsel for Defendant NETZ has no objection to the filing being 5 hours and 37

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minutes late.

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IT IS SO STIPULATED.

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Dated this 4th Day of October, 2016

Dated this 4th Day of October, 2016

/s/ Casey D. Gish
____________________________________
CASEY D. GISH, Esq.
Nevada Bar No. 6657
THE LAW OFFICE OF CASEY D. GISH
5940 S. Rainbow Blvd.
Las Vegas, NV 89118
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiffs

/s/ Todd Weiss
____________________________________
TODD WEISS, Esq.
Nevada Bar No. 14130
JOHN H. COTTON AND ASSOCIATES
7900 West Sahara Ave., #200
Las Vegas, NV 89117
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant Tanya Netz, PAC

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ORDER

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Pursuant to the terms of the attached stipulation, the Court orders as follows:

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1. Good cause exists for the retroactive extension of the due date for Plaintiffs’

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Opposition to Defendant NETZ’s Motion to Dismiss (ECF 12).
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2. The due date for the Opposition is retroactively extended to October 4, 2016.

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IT IS SO ORDERED.

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__________________________
________________________________________
RICHARD F. BOULWARE, JUDGE
UNITED STATES DISTRICTII
United States District Judge
October 10, 2016.
DATED: _________________________

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THE LAW OFFICE OF CASEY D. GISH
5940 S. Rainbow Blvd.
Las Vegas, Nevada 89118
Phone [phone]

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