McMullen v. Hunter Warfield of New England, Inc.

Filing 60

ORDER Granting 59 Stipulation to Extend Time to Reply re: 51 Motion for Attorney Fees. Replies due by 1/12/2018. Signed by Judge Jennifer A. Dorsey on 1/5/2018. (Copies have been distributed pursuant to the NEF - MMM)

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ALVERSON, TAYLOR,
MORTENSEN & SANDERS
Trevor Waite
Nevada Bar No. 13779
7401 W. Charleston Blvd.
Las Vegas, Nevada 89117-1401
T: [phone]
F: [phone]
[e-mail]

GESUND & PAILET, LLC
KEREN E. GESUND, ESQ.
Nevada Bar No. 10881
5550 Painted Mirage Rd.
Suite 320
Las Vegas, NV 89149
Tel: [phone]
Fax: [phone]
[e-mail]

CARLSON & MESSER LLP
David J. Kaminski (CA SBN: 128509)
Appearing Pro Hac Vice
[e-mail]
Tamar Gabriel (CA SBN: 266860)
Appearing Pro Hac Vice
[e-mail]
5901 W. Century Blvd., Suite 1200
Los Angeles, California 90045
Tel: [phone]
Fax: [phone]
Attorneys for Defendant,
HUNTER WARFIELD
OF NEW ENGLAND, INC.

HORWITZ, HORWITZ &
ASSOCIATES
O. Randolph Bragg
25 East Washington Street, Suite 900
Chicago, IL 60602
[phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JUSTINE MCMULLEN, an individual, on
behalf of herself and those similarly situated;

Case No.: 2:16-cv-01646

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Plaintiffs,
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vs.
HUNTER WARFIELD OF NEW ENGLAND,
INC., a Florida corporation,

ORDER GRANTING STIPULATION TO
EXTEND TIME FOR PLAINTIFF TO
FILE REPLY IN SUPPORT OF
PLAINTIFF’S MOTION FOR
ATTORNEY FEES

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[ECF No. 59]

Defendant.
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TO THIS HONORABLE COURT:
Plaintiff, JUSTINE MCMULLEN (“Plaintiff”) and Defendant, HUNTER WARFIELD OF
NEW ENGLAND, INC. (“Defendant”), by and through undersigned counsel, hereby stipulate and

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agree as follows:

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WHEREAS, on October 11, 2017, Plaintiff filed a Motion for An Award of Attorney Fees
and Costs (Dkt. No. 51) (hereinafter “Motion”);
WHEREAS, the parties met and conferred and agreed to provide Defendant an extension
of time through December 22, 2017 to file an Opposition to Plaintiff’s Motion.

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WHEREAS, on November 22, 2017, this Honorable Court granted the stipulation and
extended Defendant’s response deadline through December 22, 2017. (Dkt. No. 54).
WHEREAS, on December 22, 2017 (the Friday before Christmas), Defendant filed its

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Opposition to Plaintiff’s Motion. (Dkt. No. 56).

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WHEREAS Defendant’s opposition contains numerous statements of law and fact that

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Plaintiff would like to respond to.
WHEREAS, Plaintiff’s counsel was out of the office during the holidays and needs
additional time to reply to Defendant’s Opposition.

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WHEREAS, the parties have met and conferred and this time agreed to provide Plaintiff an

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extension of time through January 12, 2018, to file a Reply in Support of her Motion.
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WHEREAS, this request is not made for any improper purpose or delay;
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WHEREAS, the parties further agree that the granting of this request will not cause any
prejudice to them because the Hearing on Plaintiff’s Motion for Attorney’s Fees and Costs is not
scheduled to be heard until February 23, 2018.
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NOW THEREFORE, the parties respectfully request that this Court issue an order granting

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Plaintiff an extension through January 12, 2018, to file a Reply in support of Plaintiff’s Motion for

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an Award of Attorneys’ Fees and Costs, currently set for hearing on February 23, 2018 at 9:00 a.m.

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IT IS SO STIPULATED.

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Respectfully submitted,

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Plaintiff:

Defendant:

DATED this 4th day of January, 2018
GESUND & PAILET, LLC

DATED this 4th day of January, 2018
CARLSON & MESSER LLP

By: /s/ Keren E. Gesund, Esq.
KEREN E. GESUND, ESQ.
Nevada Bar No. 10881
5550 Painted Mirage Rd.
Suite 320
Las Vegas, NV 89149
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

By: /s/ Tamar Gabriel, Esq.
TAMAR GABRIEL, ESQ.
Appearing Pro Hac Vice
California Bar No. 266860
5959 W. Century Blvd., Suite 1214
Los Angeles, CA 90045
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Defendant

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IT IS SO ORDERED:

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January 5, 2018
DATED:_________________

______________________________
Hon. Jennifer A. Dorsey
UNITED STATES DISTRICT COURT JUDGE

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