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

Filing 61

ORDER Granting 58 Stipulation for Extension of Time Re: 51 Motion for Summary Judgment; Response Due 9/12/19; Reply Due 10/3/19, 52 Motion for Summary Judgment; Response Due 9/13/19; Reply Due 10/4/19, 53 Motion for Summary Judgment; R esponse Due 9/17/19; Reply Due 10/7/19, 54 Motion to Strike and 55 Motion to Bifurcate Trial; Response Due 9/10/19; Reply Due 9/24/19. Signed by Judge Richard F. Boulware, II on 9/5/2019. (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
[phone] Tel.
[phone] Fax
[e-mail]

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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
(Second 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 (Second Request) for Plaintiff to respond to
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Defendant’s following Motions:

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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; 1st Extension Response due September 5, 2019.
2. Motion for Summary Judgment on Title VII Claim (ECF #52) filed on August 9, 2019 –
Response due on August 30, 2019; 1st Extension Response due September 6, 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; 1st Extension

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Response due September 10, 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; 1st Extension Response due September 3, 2019.

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This request is made due to additional unforeseen professional and personal attentions of

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Plaintiff’s counsel. As responses are required for the Motions, the last one being due on September

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10, 2019, the parties have agreed to extend the response time for each of the Motions one week

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from each of the respective due dates. Defendant’s replies to Plaintiff’s responses will also be

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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’ second 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 12, 2019

October 3, 2019

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2. Motion – ECF #52

September 13, 2019

October 4, 2019

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3. Motion – ECF #53

September 17, 2019

October 7, 2019

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4. Motion – ECF #54 and ECF #55

September 10, 2019

September 24, 2019

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Document Number

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Dated this 4th day of September 2019.

Dated this 4th day of September 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
[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

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IT IS SO ORDERED:

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________________________________
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
IT IS SOthis 5th day of September, 2019.
DATED ORDERED.
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___________________________________

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UNITED STATES DISTRICT JUDGE

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DATED:_________________________, 2019.

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CERTIFICATE OF SERVICE
I certify that on the 4th day of September 2019, I electronically filed the foregoing
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFF TO

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RESPOND TO DEFENDANT’S MOTIONS AND FOR DEFENDANT TO REPLY (Second
Request) with the Clerk of the Court by using the ECF system.
Dated this 4th day of September 2019.

By:
/s/ Freda P. Brazier
An employee of Hatfield & Associates, Ltd.

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