Yousif v. The Venetian Casino Resort, LLC et al

Filing 155

ORDER. IT IS ORDERED that 154 the Parties' Stipulation and Briefing Schedule on Plaintiffs' motion for protective order is GRANTED. IT IS FURTHER ORDERED that the Parties will submit a Joint Status Report and Proposed Briefing Schedule no later than 14 days following final resolution of Plaintiffs' motion for protective order. Signed by Judge Richard F. Boulware, II on 2/11/2020. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:16-cv-02941-RFB-NJK Document 155 Filed 02/11/20 Page 1 of 3

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DLA PIPER LLP
Mary C. Dollarhide, admitted pro hac vice
4365 Executive Drive, Suite 1100
San Diego, CA 82121
Tel, [phone]
Fax [phone]
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK, &
STEWART, PC.
Molly M. Rezac, Nev. Bar No. 7435
50 West Liberty Street, Suite 920
Reno, Nevada 89501
Tel. [phone]
Fax [phone]
[e-mail]
Attorneys for Defendant The Venetian Casino Resort, LLC
THIERMAN BUCK, LLP
Mark R. Thierman, Esq., Bar No. 8285
Joshua D. Buck, Esq., Bar No. 12187
Leah L. Jones, Esq., Bar No. .13161
7287 Lakeside Drive
Reno, Nevada 89511
Tel. [phone]
Fax [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiffs Yousif and Walker
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
MUSTAFA YOUSIF and SHARONE WALKER )
on behalf of themselves and all others similarly )
situated,
)
)
Plaintiffs,
)
)
v.
)
)
THE VENETIAN CASINO RESORT, LLC;
)
LAS VEGAS SANDS, CORP and DOES 1
)
through 50, inclusive,
)
)
Defendants.
)

CASE NO. 2:16-cv-02941-RFB-NJK
JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
BRIEFING SCHEDULE ON
PLAINTIFFS’ MOTION FOR
PROTECIVE ORDER

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULING

Case 2:16-cv-02941-RFB-NJK Document 155 Filed 02/11/20 Page 2 of 3

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Pursuant to this Court’s Order to stay this action pending mediation, the parties hereby
submit the following briefing schedule and stipulate to other related dates herein.

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As previously reported to the Court, the Parties attended mediation on November 21, 2019,

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but were unable to reach a settlement agreement on that date. The Parties agreed to attend a

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second mediation on February 28, 2020. In the meantime, further case assessment was conducted

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and the second day of mediation was ultimately cancelled. Having met and conferred, the parties

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now jointly request the following briefing schedule with respect to the Parties’ ongoing discovery

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dispute and Plaintiffs’ previously filed motion for protective order:

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

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February 21: Plaintiffs to re-file protective order motion related to opt-in discovery
propounded on conditionally certified 216(b) collective.

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

March 20: Defendant to respond to re-filed motion for protective order.

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

April 3: Plaintiffs to file reply on motion for protective order.

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Resolution of this discovery dispute will dictate the need for additional motion practice in this case

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and the timing of such motion(s). As a result, the Parties believe that resolution of Plaintiffs’

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motion for a protective order will provide clarity on future dates so that the Parties will be in a

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better position to propose additional briefing on those motions. Therefore, the Parties further

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stipulate that Plaintiffs will withdraw their pending Rule 23 class certification motion and the

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Parties will submit a joint briefing schedule on any future Rule 23 motion (and other potential

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motions) no later than 14 days following the Court’s final resolution on Plaintiffs’ motion for

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protective order.

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This Stipulation is made in good faith and not for the purposes of undue burden or delay.
IT IS SO STIPULATED:
Dated this 10th day of February, 2020.
THIERMAN BUCK, LLP

Dated this 10th day of February, 2020.
DLA PIPER LLP

/s/Joshua D. Buck
Mark R. Thierman, Esq., Bar No. 8285
Joshua D. Buck, Esq., Bar No. 12187
Leah L. Jones, Esq., Bar No. .13161
7287 Lakeside Drive
Reno, Nevada 89511

/s/Mary C. Dollarhide
Mary C. Dollarhide, admitted pro hac vice
4365 Executive Drive, Suite 1100
San Diego, CA 82121
OGLETREE, DEAKINS, NASH, SMOAK, &

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULING

Case 2:16-cv-02941-RFB-NJK Document 155 Filed 02/11/20 Page 3 of 3

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STEWART, P.C.
Attorneys for Plaintiffs
/s/Molly M. Rezac
Molly M. Rezac, Nev. Bar No. 7435
50 West Liberty Street, Suite 920
Reno, Nevada 89501

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Attorneys for Defendant

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ORDER
IT IS HEREBY ORDERED that the Parties’ Stipulation and Briefing Schedule on
Plaintiffs’ motion for protective order is GRANTED.
IT IS FURTHER ORDERED that the Parties will submit a Joint Status Report and
Proposed Briefing Schedule no later than 14 days following final resolution of Plaintiffs’ motion
for protective order.
IT IS SO ORDERED:

________________________________
______________________________________
UNITED BOULWARE, II
RICHARD F.STATES DISTRICT COURT JUDGE
UNITED STATES DISTRICT JUDGE
DATED:
, 2020
DATED this 11th day of February , 2020.

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JOINT STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULING