Cosper v. Titanium Metals Corporation

Filing 34

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)

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Case 2:16-cv-01548-JCM-CWH Document 33 Filed 02/07/18 Page 1 of 2 5 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 6 Attorney for Plaintiff 1 2 3 4 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 DAVID COSPER, an individual, 11 12 13 14 15 16 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. 17 COMES NOW, Plaintiff, DAVID COSPER (hereinafter “Plaintiff”), by and through his 18 counsel, the law firm of Hatfield & Associates, Ltd., and Defendant TITANIUM METALS 19 CORPORATION (hereinafter “Defendant”), by and through its counsel, OGLETREE, DEAKINS, 20 21 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 23 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). 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 24 28 22 25 The reason that the extension is requested is because the parties have agreed to extend the 26 dispositive motion deadline. On December 28, 2017, the Court granted Defendant’s extension to 27 file dispositive motions, which confirmed that Plaintiff’s response would be due 35 days after 28 Defendant’s Motion for Summary Judgment was filed. (ECF #28.) On January 11, 2018, 1 Case 2:16-cv-01548-JCM-CWH Document 33 Filed 02/07/18 Page 2 of 2 1 Defendant filed a request asking that both parties have an additional ten (10) days to file dispositive 2 motions and a reciprocal additional ten (10) days’ time for any response. (ECF #29.) The Court 3 4 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 5 6 7 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 8 parties’ first request for an extension concerning an extension of the time for Plaintiff to respond to 9 dispositive motions deadline. Plaintiff’s attorney is requesting this extension of the parties’ 10 agreement (ECF #29) and because he has significant conflicts in his work schedule including 11 fourteen (14) depositions, three (3) hearings and two (2) settlement conferences scheduled through 12 the last week of January through the first week of March 2018. 13 Dated: February 7, 2018 Dated: February 7, 2018 15 HATFIELD & ASSOCIATES, LTD. OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 16 /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 __________________________________ 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 14 17 18 19 20 21 28 22 23 IT IS SO ORDERED. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 24 25 February 9, 2018. Dated this ___ day of_________________________, 2018. 26 27 _________________________________ UNITED STATES DISTRICT JUDGE 28 2

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