U.S. Equal Employment Opportunity Commission v. Wynn Las Vegas, LLC

Filing 45

ORDER Granting 44 Stipulation to Extend Time. Proposed Joint Pretrial Order due by 10/31/2018. Signed by Judge Richard F. Boulware, II on 8/10/2018. (Copies have been distributed pursuant to the NEF - ADR)

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Anna Y. Park, CA SBN 164242
Sue J. Noh, CA SBN 192134
Rumduol Vuong, CA SBN 264392
Derek W. Li, CA SBN 150122
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Plaintiff,
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vs.
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WYNN LAS VEGAS, LLC; and DOES 1-10, )
INCLUSIVE,
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Defendants.
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EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,

Case No.: 2:16-cv-02187-RFB-PAL
JOINT STIPULATION FOR AN ORDER
CONTINUING THE DEADLINE TO
SUBMIT A PROPOSED JOINT
PRETRIAL ORDER; [PROPOSED]
ORDER; CERTIFICATE OF SERVICE
[Second Request]
Honorable Richard F. Boulware, II
United States District Judge

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Plaintiff United States Equal Employment Opportunity Commission ("EEOC") and

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Defendant Wynn Las Vegas, LLC (“Wynn”), by and through their undersigned counsel,

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respectfully request that the Court extend the deadline for the parties to submit their Proposed

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Joint Pretrial Order in this case due to their concurrent request to continue to the settlement

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conference due to a scheduling conflict for the EEOC’s counsel. In support of this stipulation

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and request, the parties state as follows:

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1.

On July 10, 2018, the Court denied Wynn’s Motion for Summary Judgment and

the EEOC’s Motion for Partial Summary Judgment. (ECF No. 38). The Court ordered both

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parties to be referred to the Magistrate Judge for the purposes of scheduling a settlement

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conference. (Id.). The Court also ordered the parties to submit a Proposed Joint Pretrial Order

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by August 31, 2018.

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2.

Upon the parties’ stipulation, the Court on July 18, 2018 ordered the deadline for

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the parties to file a Proposed Joint Pretrial Order be extended to October 31, 2018 to allow

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additional time for a settlement conference to be scheduled to see if the case can be resolved

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before expending further resources for trial. (ECF No. 40).

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3.

Subsequent to the Court’s July 18, 2018 Order, Magistrate Judge Leen ordered a

settlement conference for October 25, 2018. (ECF No. 42). Due to a conflict with a trial for

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EEOC’s counsel of record, the parties have concurrently filed a stipulation requesting the

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settlement conference be scheduled to a date starting in late November or early December 2018.

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4.

The parties submit this second request for an extension of the deadline to file a

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Proposed Joint Pretrial Order to six (6) weeks after the settlement conference to be rescheduled

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by Magistrate Judge Leen.

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5.

The EEOC and Wynn request an extension of the Proposed Joint Pretrial Order

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deadline until after the settlement conference is held to conserve resources to maximize the

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chances of settlement. With the current deadline for the submission of a Proposed Joint Pretrial

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Order by October 31, 2018, the parties’ resources and attention would need to be diverted to

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prepare a Proposed Joint Pretrial Order. Such resources may be better served to attempt to settle

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the case first before preparing for trial.

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6.

Thus, the parties request an Order extending the deadline to submit a Proposed

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Joint Pretrial Order from October 31, 2018 to a date six (6) weeks after the settlement

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conference to be rescheduled by Magistrate Judge Leen.

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//

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//

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7.

This second request to extend the deadline to submit a Proposed Joint Pretrial

Order is for the reasons stated, and not for any improper reason or delay.

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Dated: August 9, 2018

Dated: August 9, 2018

/s/ Derek W. Li
Derek W. Li

/s/ Scott M. Abbott
Scott M. Abbott
#4500
Nicole A. Young #13423
Kamer Zucker Abbott
3000 West Charleston Blvd., Suite 3
Las Vegas, NV 89102
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Wynn Las Vegas, LLC

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff

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[PROPOSED] ORDER UPON STIPULATION

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For good cause shown, IT IS SO ORDERED.

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August 10, 2018.
Dated: __________________

______________________________________
RICHARD F. BOULWARE, II
United States District Judge

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Anna Y. Park, CA SBN 164242
Sue J. Noh, CA SBN 192134
Rumduol Vuong, CA SBN 264392
Derek Li CA SBN 150122
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
255 East Temple Street, Fourth Floor
Los Angeles, CA 90012
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Nechole M. Garcia, NV SBN 12746
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION
333 Las Vegas Boulevard South, Suite 5560
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Plaintiff
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,

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Plaintiff,

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vs.
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WYNN LAS VEGAS, LLC,
Defendant.

) Case No: 2:16-cv-02187-RFB-PAL
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) CERTIFICATE OF SERVICE
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CERTIFICATE OF SERVICE

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I am, and was at the time the herein mentioned delivery took place, a citizen of the

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United States, over the age of eighteen (18) years.
I am employed in the Legal Unit of the Los Angeles District Office of the United States
Equal Employment Opportunity Commission.
My business address is U.S. Equal Employment Opportunity Commission, Los Angeles
District Office, 255 East Temple Street, 4th Floor, Los Angeles, California 90012.
On the date that this declaration was executed, as shown below, I served the following:
1. JOINT STIPULATION FOR AN ORDER CONTINUING THE DEADLINE
TO SUBMIT A PROPOSED JOINT PRETRIAL ORDER; [PROPOSED]
ORDER; CERTIFICATE OF SERVICE

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via the Court’s CMECF electronic filing system and/or first class mail / email to Defendant’s

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counsel:

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Scott M. Abbott
Kamer Zucker & Abbott
3000 West Charleston Blvd, Suite 3
Las Vegas, NV 89102
[e-mail]

Nicole A. Young
Kamer Zucker & Abbott
3000 West Charleston Blvd., Suite 3
Las Vegas, NV 89102
[e-mail]

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I declare under penalty of perjury that the foregoing is true and correct. Executed on July
17, 2018.
/s/ Derek Li
Derek Li

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