Keen et al v. Omni Limousine

Filing 32

ORDER Granting 31 Stipulation for Extension of Time 27 Motion to Lift Stay and 28 Motion for a Briefing Schedule. Responses due by 4/21/2017. Signed by Magistrate Judge George Foley, Jr on 4/10/17. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6

GARG GOLDEN LAW FIRM
ANTHONY B. GOLDEN, ESQ.
Nevada Bar No. 9563
MARGARET G. FOLEY, ESQ.
Nevada Bar No. 7703
3185 St. Rose Parkway, Suite 325
Henderson, Nevada 89052
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

7
Counsel for Defendant Omni Limousine
8
9
10

UNITED STATES DISTRICT COURT

11

DISTRICT OF NEVADA

12

RONALD KEEN, ET AL.,
CASE NO.: 2:16-cv-01903-JCM-GWF
Plaintiffs,

13
14

vs.

15
OMNI LIMOUSINE,
16
Defendant.

STIPULATION AND [PROPOSED[
ORDER TO EXTEND DEADLINES TO
RESPOND TO MOTION TO LIFT STAY
(ECF No. 27) and MOTION FOR
BRIEFING SCHEDULE RE MOTION
FOR CIRCULATION OF NOTICE (ECF
No. 28)

17
(First Request)
18
19

Plaintiffs, by and through their counsel of record, Thierman Buck, LLP, and Defendant, by

20

and through its counsel of record, the Garg Golden Law Firm, hereby stipulate and agree as

21

follows:

22
23
24

1.

To an extension of Defendant’s deadline to respond to Plaintiffs’ Motion to Lift

Stay (ECF No. 27) from April 7, 2017, to April 21, 2017; and
2.

To an extension of Defendant’s deadline to respond to Plaintiffs’ Motion for

25

Briefing Schedule re Motion for Circulation of Notice (ECF No. 28) from April 7, 2017, to April

26

21, 2017.

27

On March 30, 2017, Plaintiffs filed their Motion to Lift Stay (ECF No. 27) and Motion for

28

Briefing Schedule re Motion for Circulation of Notice (ECF No. 28). On March 31, 2017, the

GARG GOLDEN
LAW FIRM
3185 St. Rose Parkway
Suite 325
Henderson, Nevada 89052
[phone]

1 of 2

1

Court ordered Defendant to file any opposition to the foregoing motions no later than April 7, 2017

2

(ECF. No. 30). Since the Court’s Order, the parties have engaged in good faith discussions, through

3

their counsel, to submit this case and the related case, McSwiggin v. Omni Limousine, Case No

4

2:14-cv-02172-JCM-NJK, to mediation. Accordingly, the parties wish to dedicate time and

5

financial resources toward that end. The parties anticipate reaching an agreement on submitting

6

the cases to mediation within 14 days of today and, therefore, request that the Court extend

7

Defendant’s opposition deadline on the respective motions 14 days from today to April 21, 2017.

8

Provided the parties reach an agreement regarding mediation in that time, they will submit to the

9

Court a further stipulation regarding the stay.

10

This stipulation is not made for the purposes of delay but to allow the parties sufficient

11

time to reach an agreement on a mediator and to initiate the mediation process. This is the first

12

request for an extension of these deadlines.

13

DATED this 7th day of April, 2017.

DATED this 7th day of April, 2017

14

GARG GOLDEN LAW FIRM

THIERMAN BUCK, LLP

15

By /s/ Anthony B. Golden
Anthony B. Golden, Esq.
Margaret G. Foley, Esq.
3185 St. Rose Parkway, Suite 325
Henderson, Nevada 89052
[phone]

By /s/ Joshua D. Buck
Joshua D. Buck, Esq.
Mark R. Thierman, Esq.
Joshua R. Hendrickson, Esq.
7287 Lakeside Drive
Reno, Nevada 89511

16
17
18

Counsel for Defendant

Counsel for Plaintiffs

19
20
21
22

ORDER
IT IS SO ORDERED:

23
24
25

UNITED STATES MAGISTRATE JUDGE

26
27

DATED: April 10, 2017

28
GARG GOLDEN
LAW FIRM
3185 St. Rose Parkway
Suite 325
Henderson, Nevada 89052
[phone]

2 of 2