Slaton v. L.L.O., Inc. et al

Filing 57

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)

5

TREVOR J. HATFIELD, ESQ.
Nevada Bar No. 7373
HATFIELD & ASSOCIATES, LTD.
703 South Eighth Street
Las Vegas, Nevada 89101
[phone] Tel.
[phone] Fax
[e-mail]

6

Attorney for Plaintiff

1
2
3
4

7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9
10

MALINDA SLATON, an individual,
Plaintiff,

11
vs.

12
13
14
15

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)

16
Defendants.
17
18
COMES NOW, Plaintiff MALINDA SLATON, (hereinafter, “SLATON”), by and

20

through her attorney of record Trevor J. Hatfield of the law firm of Hatfield & Associates, Ltd.,

21

and L.L.O. INC., d/b/a ACME ELECTRIC’s (hereinafter “ACME ELECTRIC) and do hereby

22

28

19

stipulate and agree to an extension of time for Plaintiff to respond to Defendant’s following

23
Motions as follows:

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

24
25
26
27
28

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;
1

3. Third Motion for Partial Summary Judgment to Limit Plaintiff’s Categories of Damages

1
2

(ECF #53) filed on August 12, 2019 – Response due on September 2, 2019;

3

4. Motion to Strike Jury Demand or, in the Alternative, to Bifurcate Liability and Damages

4

Phases of Trial (ECF #54 and ECF #55) filed on August 13, 2019 – Response due on

5
August 27, 2019.

6

The reason the extension is requested is that Plaintiff’s attorney is scheduled for dental

7
8

surgery on Tuesday, August 27, 2019, and will require one day for recovery. In addition, the Labor

9

Day Holiday weekend is August 31 through September 2, 2019. As responses are required for the

10

Motions, the last one being due on September 2, 2019, the parties have agreed to extend the

11

response time for each of the Motions one week from each of the respective due dates. Defendant’s

12
replies to Plaintiff’s responses will also be extended by one week respectively.
13
This request is submitted pursuant to LR IA 6-1, 6-2 and LR II 7-1 and 26-4 and is the

14
15

parties’ first request for an extension of the time for the parties to respond to the various motion

16

response deadlines. Accordingly, Plaintiff’s proposed response dates and Defendant’s proposed

17

reply dates shall be as follows:

18

///

19

///

20
///
22

///
///

24

///

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

23

28

21

25
26
27

///
///
///

28

2

Proposed
Response Due Date

Proposed
Reply Due Date

1. Motion - ECF #51

September 5, 2019

September 26, 2019

4

2. Motion – ECF #52

September 6, 2019

September 27, 2019

5

3. Motion – ECF #53

September 10, 2019

September 30, 2019

6

4. Motion – ECF #54 and ECF #55

September 3, 2019

September 17, 2019

1
2
3

Document Number

7
8

Dated this 27th day of August 2019.

Dated this 27thth day of August 2019.

9

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
[phone] Tel.
Email: [e-mail]
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: [phone]
Email: [e-mail]
Attorneys for Defendant L.L.O. Inc. d/b/a Acme
Electric

10
11
12
13
14
15
16
17
18
19
20
21

23

___________________________________
________________________________
UNITED STATES DISTRICT JUDGE
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

24

IT IS SO ORDERED.
28

22

25
26

DATED this 28th day of August, 2019.
DATED:_________________________, 2019.

27
28

3

1
2
3
4

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

5
6
7

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.

8
9
10
11
12
13
14
15
16
17
18
19
20

22

28

21

23

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27

24
25
26
27
28

4