United States of America, ex rel et al v. Fife Dermatology PC et al

Filing 76

ORDER Granting 75 Stipulation for Extension of Time Re: 71 Motion for Summary Judgment, Responses due by 3/28/2022. Signed by Judge James C. Mahan on 3/4/2022. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:17-cv-02191-JCM-EJY Document 75 Filed 03/03/22 Page 1 of 3

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JAMES P. KEMP, ESQUIRE
Nevada Bar No. 006375
KEMP & KEMP, ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110,
Las Vegas, NV 89130
[phone] tel./[phone] fax
[e-mail]
Attorney for Plaintiff Thomas Mooney

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CASE NO. 2:17-cv-02191-JCM-DJA

THOMAS MOONEY,

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Plaintiff,

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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT

v.
FIFE DERMATOLOGY, PC, d/b/a
SURGICAL DERMATOLOGY & LASER
CENTER; DOUGLAS FIFE, M.D.; and
HEATHER FIFE,
.

(First Request)

Defendants.

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The parties, by and through their respective counsel, hereby stipulate to extend the time

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for Plaintiff to respond to Defendants’ MOTION FOR SUMMARY JUDGMENTOPPOSITION

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TO PLAINTIFF’S MOTION FOR LEAVE TO FILE SECOND AMENDED COMPLAINT

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(ECF No. 71) from the current due date of Friday, March 4, 2022 through and including
Monday, March 28, 2022.
This is the first request for an extension of this deadline. The parties provide the
following information to the Court regarding the proposed extension of time:

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1. Plaintiff’s counsel has been delayed in completing work over the past

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several weeks due to a busy litigation calendar. Plaintiff’s counsel was out

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Case 2:17-cv-02191-JCM-EJY Document 75 Filed 03/03/22 Page 2 of 3

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of state when the Motion was filed and did not return until February 14,

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2022. On February 14, 2022 Plaintiff’s counsel had oral argument before

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the Ninth Circuit Court of Appeals. That same day after that argument

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Plaintiff’s counsel travelled to Elko, Nevada for six (6) depositions over

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three days from February 15-17, 2022. The following week was a short

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week due to President’s Day. Plaintiff’s counsel had an important deadline

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on February 22 in a discovery dispute before Magistrate Judge Denney and

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an all day mediation to prepare for and attend on February 24 with Retired

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Magistrate Judge Leen. Plaintiff’s counsel then had to travel to Reno for

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an all day deposition on March 1 and all day depositions in Elko on March

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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2 and 3.

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2. Plaintiff’s counsel also will be leaving on March 4, 2022 for a long-planned

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two week cruise vacation where he and his wife are celebrating their 25th

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wedding anniversary. Plaintiff’s counsel will have no time to work on the

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response to Defendants’ comprehensive motion seeking summary

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judgment on all claims until at least March 21, 2022. That is why an

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extension to March 28, 2022 is being sought.

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3. The Parties have further agreed to an extension to the Reply deadline for

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Defendants to April 18, 2022.

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4. There are no other deadlines or proceedings with which this extension

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would interfere.
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///

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Case 2:17-cv-02191-JCM-EJY Document 75 Filed 03/03/22 Page 3 of 3

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This stipulation to extend the Response and Reply deadlines on Defendants’ Motion for

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Summary Judgment is made in good faith and not for purposes of delay.

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DATED this 3rd day of March, 2022.

DATED this 3rd day of March, 2022.

___/s/ Hayley Cummings
P. SWEN PRIOR, ESQ.
HAYLEY CUMMINGS, ESQ,
SNELL & WILMER
3883 Howard Hughes Pkwy., #1100
Las Vegas, NV 89169
Attorney for Defendants

/s/ James P. Kemp
JAMES P. KEMP, ESQ.
Bar No. 6375
KEMP & KEMP, Attorneys at Law
7435 W. Azure Drive, Suite 110
Las Vegas, NV 89130
Attorney for Plaintiff

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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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ORDER

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IT IS SO ORDERED:
____________________________________
UNITED STATES DISTRICT JUDGE
March 4, 2022
DATED: ________________________

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