Slaton v. L.L.O., Inc. et al
Filing
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ORDER Granting 56 Stipulation for Extension of Time Re: 51 Motion for Summary Judgment Responses Due by 9/5/19; Replies due by 9/26/19, 52 Motion for Summary Judgment Responses Due by 9/6/19; Replies due by 9/27/19, 53 Motion for Sum mary Judgment Responses Due by 9/10/19; Replies due by 9/30/19, 54 Motion to Strike and 55 Motion to Bifurcate Trial Responses Due by 9/3/19; Replies due by 9/17/19. Signed by Judge Richard F. Boulware, II on 8/28/2019. (Copies have been distributed pursuant to the NEF - JQC)
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TREVOR J. HATFIELD, ESQ.
Nevada Bar No. 7373
HATFIELD & ASSOCIATES, LTD.
703 South Eighth Street
Las Vegas, Nevada 89101
(702) 388-4469 Tel.
(702) 386-9825 Fax
thatfield@hatfieldlawassociates.com
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Attorney for Plaintiff
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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MALINDA SLATON, an individual,
Plaintiff,
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vs.
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CASE NO: 2:17-cv-01561-RFB-DJA
L.L.O. INC., d/b/a ACME ELECTRIC, a domestic
corporation; INTERNATIONAL BROTHERHOOD
OF ELECTRICAL WORKERS LOCAL UNION
357, a domestic not for profit corporation; DOES I
through X, inclusive; ROE CORPORATIONS I
through X, inclusive,
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PLAINTIFF TO RESPOND TO
DEFENDANT’S MOTIONS AND FOR
DEFENDANT TO REPLY
(First Request)
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Defendants.
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COMES NOW, Plaintiff MALINDA SLATON, (hereinafter, “SLATON”), by and
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through her attorney of record Trevor J. Hatfield of the law firm of Hatfield & Associates, Ltd.,
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and L.L.O. INC., d/b/a ACME ELECTRIC’s (hereinafter “ACME ELECTRIC) and do hereby
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stipulate and agree to an extension of time for Plaintiff to respond to Defendant’s following
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Motions as follows:
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1.
Motion for Summary Judgment on Breach of Contract Claim (ECF #51) filed on August 8,
2019 – Response due on August 29, 2019;
2. Motion for Summary Judgment on Title VII Claim (ECF #52) filed on August 9, 2019 –
Response due on August 30, 2019;
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3. Third Motion for Partial Summary Judgment to Limit Plaintiff’s Categories of Damages
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(ECF #53) filed on August 12, 2019 – Response due on September 2, 2019;
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4. Motion to Strike Jury Demand or, in the Alternative, to Bifurcate Liability and Damages
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Phases of Trial (ECF #54 and ECF #55) filed on August 13, 2019 – Response due on
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August 27, 2019.
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The reason the extension is requested is that Plaintiff’s attorney is scheduled for dental
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surgery on Tuesday, August 27, 2019, and will require one day for recovery. In addition, the Labor
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Day Holiday weekend is August 31 through September 2, 2019. As responses are required for the
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Motions, the last one being due on September 2, 2019, the parties have agreed to extend the
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response time for each of the Motions one week from each of the respective due dates. Defendant’s
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replies to Plaintiff’s responses will also be extended by one week respectively.
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This request is submitted pursuant to LR IA 6-1, 6-2 and LR II 7-1 and 26-4 and is the
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parties’ first request for an extension of the time for the parties to respond to the various motion
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response deadlines. Accordingly, Plaintiff’s proposed response dates and Defendant’s proposed
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reply dates shall be as follows:
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Proposed
Response Due Date
Proposed
Reply Due Date
1. Motion - ECF #51
September 5, 2019
September 26, 2019
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2. Motion – ECF #52
September 6, 2019
September 27, 2019
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3. Motion – ECF #53
September 10, 2019
September 30, 2019
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4. Motion – ECF #54 and ECF #55
September 3, 2019
September 17, 2019
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Document Number
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Dated this 27th day of August 2019.
Dated this 27thth day of August 2019.
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HATFIELD & ASSOCIATES, LTD.
HOLLEY DRIGGS, WALCH
FINE WRAY PUZEY & THOMPSON
/s/ Trevor J. Hatfield
By:___________________________________
Trevor J. Hatfield, Esq.
Nevada Bar No. 7373
703 S. Eighth St.
Las Vegas, NV 89101
(702) 388-4469 Tel.
Email: thatfield@hatfieldlawassociates.com
Attorney for Plaintiff
/s/ F. Thomas Edwards
By: __________________________________
F. Thomas Edwards, Esq., SBN 9549
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone: 702/791-0308
Email: tedwards@nevadafirm.com
Attorneys for Defendant L.L.O. Inc. d/b/a Acme
Electric
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___________________________________
________________________________
UNITED STATES DISTRICT JUDGE
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
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IT IS SO ORDERED.
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DATED this 28th day of August, 2019.
DATED:_________________________, 2019.
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CERTIFICATE OF SERVICE
I certify that on the 27th day of August 2019, I electronically filed the foregoing
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANT’S MOTIONS AND FOR DEFENDANT TO REPLY (First
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Request) with the Clerk of the Court by using the ECF system.
Dated this 27th day of August 2019.
By:
/s/ Freda P. Brazier
An employee of Hatfield & Associates, Ltd.
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