Cosper v. Titanium Metals Corporation
Filing
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ORDER Granting 31 Stipulation to Extend Time Re: 30 Motion for Summary Judgment. Responses due by 3/8/2018. Signed by Judge James C. Mahan on 2/9/2018. (Copies have been distributed pursuant to the NEF - ADR)
Case 2:16-cv-01548-JCM-CWH Document 33 Filed 02/07/18 Page 1 of 2
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TREVOR J. HATFIELD, ESQ.
Nevada Bar No. 7373
HATFIELD & ASSOCIATES, LTD.
703 South Eighth Street
Las Vegas, Nevada 89101
(702) 388-4469 Tel.
(702) 386-9825 Fax
thatfield@hatfieldlawassociates.com
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Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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DAVID COSPER, an individual,
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CASE NO: 2:16-cv-01548-JCM-CWH
Plaintiff,
vs.
TITANIUM METALS CORPORATION, a
Domestic Corporation; DOES I through X,
inclusive; ROE CORPORATIONS I through X,
inclusive,
STIPULATION AND [PROPOSED]
ORDER REQUESTING TIME TO
RESPOND TO DEFENDANT’S
MOTION FOR SUMMARY
JUDGMENT
(First Request)
Defendants.
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COMES NOW, Plaintiff, DAVID COSPER (hereinafter “Plaintiff”), by and through his
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counsel, the law firm of Hatfield & Associates, Ltd., and Defendant TITANIUM METALS
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CORPORATION (hereinafter “Defendant”), by and through its counsel, OGLETREE, DEAKINS,
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NASH, SMOAK & STEWART, P.C., and do hereby stipulate and agree to an extension of time for
Plaintiff to respond to Defendant’s Motion for Summary Judgment (ECF #30), that was filed on
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January 22, 2018. Accordingly, Plaintiff shall have up to and including March 8, 2018 to respond
to Defendant’s Motion for Summary Judgment (ECF #30).
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The reason that the extension is requested is because the parties have agreed to extend the
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dispositive motion deadline. On December 28, 2017, the Court granted Defendant’s extension to
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file dispositive motions, which confirmed that Plaintiff’s response would be due 35 days after
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Defendant’s Motion for Summary Judgment was filed. (ECF #28.) On January 11, 2018,
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Case 2:16-cv-01548-JCM-CWH Document 33 Filed 02/07/18 Page 2 of 2
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Defendant filed a request asking that both parties have an additional ten (10) days to file dispositive
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motions and a reciprocal additional ten (10) days’ time for any response. (ECF #29.) The Court
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has not issued an order on this stipulation, but Defendant filed its Motion for Summary Judgment
on January 22, 2018 (ECF #30). Defendant agrees to Plaintiff having forty-five (45) days after
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January 22, 2018 to respond, which is March 8, 2018.
This request is submitted pursuant to LR IA 6-1, 6-2 and LR II 7-1 and 26-4 and is the
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parties’ first request for an extension concerning an extension of the time for Plaintiff to respond to
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dispositive motions deadline. Plaintiff’s attorney is requesting this extension of the parties’
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agreement (ECF #29) and because he has significant conflicts in his work schedule including
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fourteen (14) depositions, three (3) hearings and two (2) settlement conferences scheduled through
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the last week of January through the first week of March 2018.
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Dated: February 7, 2018
Dated: February 7, 2018
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HATFIELD & ASSOCIATES, LTD.
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.
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/s/ Trevor J. Hatfield
___________________________________
Trevor J. Hatfield, Esq.
Nevada Bar No. 7373
703 S. Eighth St.
Las Vegas, NV 89101
(702) 388-4469 Tel.
(702) 386-9825 Fax
thatfield@hatfieldlawassociates.com
Attorney for Plaintiff
/s/ Erica J. Chee
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Anthony L. Martin
Nevada Bar No. 8177
Erica J. Chee
Nevada Bar No. 12238
Wells Fargo Tower, Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Anthony.martin@ogletreedeakins.com
Erica.chee@ogletreedeakins.com
Attorneys for Defendant
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IT IS SO ORDERED.
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February 9, 2018.
Dated this ___ day of_________________________, 2018.
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_________________________________
UNITED STATES DISTRICT JUDGE
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