Hoffman v. Southwest Gas Corporation

Filing 32

ORDER Granting 31 Stipulation to Extend Time (Fifth Request). Amended Complaint deadline: 1/22/2018. Motions due by 2/5/2018. Proposed Joint Pretrial Order due by 3/7/2018. Signed by Judge Jennifer A. Dorsey on 1/8/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-02129-JAD-PAL Document 31 Filed 01/08/18 Page 1 of 3

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Deverie J. Christensen, Bar No. 6596
[e-mail]
Mahna Pourshaban, Bar No. 13743
[e-mail]
JACKSON LEWIS P.C.
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
Southwest Gas Corporation

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Laura Hoffman, an individual residing in
Nevada,
Plaintiff,

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v.

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Case No. 2:16-cv-02129-JAD-PAL

SOUTHWEST GAS CORPORATION, a
Nevada Registered Foreign Corporation;
ROE Corporations I through X, inclusive;
and DOES I through X, Inclusive,

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STIPULATION AND ORDER TO EXTEND
TIME TO FILE PLAINTIFF’S AMENDED
COMPLAINT AND DISPOSITIVE MOTION
DEADLINE
(Fifth Request)

Defendants.

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Pursuant to LR 26-4, all parties hereby stipulate to extend the amended complaint and
dispositive motion deadlines in this action as follows.

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I.

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1.

INTRODUCTION

On November 22, 2016, this Court entered an Order granting the Proposed

Discovery Plan and Scheduling Order submitted by the parties. ECF No. 14.

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3.

The current dispositive motion deadline is January 15, 2018.

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4.

From November 2017 through December 12, 2017 the parties engaged in

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meaningful settlement discussions, however, the parties were unable to resolve the entire matter.

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The parties subsequently reached agreement for Plaintiff to voluntarily withdraw some of her

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claims.

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JACKSON LEWIS P.C.
LAS VEGAS

5.

On December 22, 2017, the parties submitted a stipulation and order to dismiss with

Case 2:16-cv-02129-JAD-PAL Document 31 Filed 01/08/18 Page 2 of 3

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prejudice Plaintiff’s Second, Third, Fourth, Eighth, and Ninth Claims. ECF No 29.
6.

Around the December holidays, Plaintiff’s counsel, Bradley Bellisario and his

family contracted the influenza virus.
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Similarly, during the holidays Lead Defense Counsel, Deverie Christensen and her

family contracted the influenza virus.
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As the Court may already be aware from news outlets, the flu season has been

particularly bad this year.
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The parties recognize the stipulation to extend the dispositive motion deadline was

due on December 26, 2017. Due to the unforeseen illnesses experienced by counsel, the parties are
seeking a brief extension of time to meet upcoming deadlines.
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Accordingly, the parties stipulate and agree to extend the deadline for Plaintiff to

file her amended complaint (pursuant to ECF No. 30) to January 22, 2018.

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11.

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February 5, 2018.

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12.

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Further, the parties stipulate and agree to extend the dispositive motion deadline to

Additionally, the parties seek additional time for Plaintiff to respond to Defendant’s

dispositive motion. The parties request Plaintiff’s opposition be due on February 26, 2018.
II.

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PROPOSED SCHEDULE

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The parties stipulate and agree that:

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1.

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Amended Complaint: The deadline for Plaintiff to file her amended complaint

pursuant to ECF No. 30 shall be extended up to and including January 22, 2018.
2.

Dispositive Motions: The deadline to file dispositive motions shall be extended up

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to and including February 5, 2018, twenty-one days after the current dispositive motion deadline.

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Plaintiff’s opposition to Defendant’s dispositive motion will be due February 26, 2018.

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Defendant’s Reply will be submitted per the Court’s Local Rules.

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3.

Pre-Trial Order: If no dispositive motions are filed, the Joint Pretrial Order shall

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be filed thirty (30) days after the date set for the filing of dispositive motions. Therefore, the Joint

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Pretrial order shall be filed no later than March 7, 2018. In the event dispositive motions are filed,

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the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days after decision on

JACKSON LEWIS LLP
LAS VEGAS

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Case 2:16-cv-02129-JAD-PAL Document 31 Filed 01/08/18 Page 3 of 3

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the dispositive motions or by further order of the Court. The disclosures required by Federal Rules

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of Civil Procedure 26(a)(3), and any objections thereto, shall be included in the pretrial order as

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required by LR 26-1(e)(6).

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4.

Any deadline not extended in accordance with this Stipulation and Order to Extend

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Discovery Deadlines and Scheduling Order set forth above shall remain controlled by the Joint

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Discovery Plan and Scheduling Order (ECF No. 14) filed in this matter on November 22, 2016.

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This stipulation and order is sought in good faith and not for the purpose of delay. Four
prior requests for an extension of scheduling deadlines has been previously made.
DATED this 8th day of January, 2018.
BELLISARIO LAW

JACKSON LEWIS P.C.

/s/ Bradley Bellisario
Bradley Bellisario, Esq., Bar #13452
2945 N. Martin L King Blvd.
North Las Vegas, Nevada 89032
Attorney for Plaintiff

/s/ Mahna Pourshaban
Deverie J. Christensen, Bar #6596
Mahna Pourshaban, Bar #13743
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Attorney for Defendant
Southwest Gas Corporation

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ORDER

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IT IS SO ORDERED

January 8

, 2018.

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U.S. District/Magistrate Judge
UNITED STATES DISTRICT JUDGE

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4820-4566-8954, v. 1

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JACKSON LEWIS LLP
LAS VEGAS

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