Lubritz v. AIG Claims, Inc.

Filing 28

ORDER Granting 27 First Stipulation for Extension of Time Re: 24 Motion for Summary Judgment. Plaintiff's Responses due by 4/30/2018. Signed by Judge Andrew P. Gordon on 4/16/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02310-APG-NJK Document 27 Filed 04/16/18 Page 1 of 3

1 CAMPBELL & WILLIAMS
DONALD J. CAMPBELL, ESQ. (1216)
2 [e-mail]
SAMUEL R. MIRKOVICH, ESQ. (11662)
3
[e-mail]
4 700 South Seventh Street
Las Vegas, Nevada 89101
5 Tel: [phone]
Fax: [phone]
6
Attorneys for Plaintiff
7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

JOEL LUBRITZ

11
12
13

Plaintiff,
vs.

AIG CLAIMS, INC., a Delaware
14 Corporation; DOES I through X,
15 inclusive; ROE CORPORATIONS I through
X, inclusive; ROE LIMITED LIABILITY
16 COMPANIES I through X, inclusive,
17
18

Defendant.

)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:17-cv-02310-APG-NJK
STIPULATION AND [PROPOSED]
ORDER RE: EXTENSION OF TIME
FOR PLAINTIFF TO FILE OPPOSITION
TO DEFENDANT AIG CLAIMS, INC.’S
MOTION FOR SUMMARY JUDGMENT
[ECF NO 24]
[FIRST REQUEST FOR EXTENSION]

19

Pursuant to Local Rules IA 6-1 and 6-2, Plaintiff Joel Lubritz (“Plaintiff”), and Defendant

20

AIG Claims, Inc. (“Defendant”) hereby stipulate to extend the time for Plaintiff to file his

21

Opposition to Defendant AIG Claims, Inc.’s Motion for Summary Judgment [ECF No. 24].

22
23

On March 30, 2018, Defendant filed its Motion for Summary Judgment [ECF No. 24].
Plaintiff’s Opposition is scheduled to be due on Friday, April 20, 2018 but, because Plaintiff’s

24
25
26

counsel is scheduled to begin voir dire in the matter of Elaine P. Wynn v. Stephen A. Wynn et al.,
Case No. A-12-656710-C, Plaintiff’s counsel respectfully requests a ten (10) day extension in

27

which to file the Opposition. Plaintiff submits that good cause exists to approve this stipulation

28

because of his counsel’s current trial schedule and, moreover, because the Parties are currently

Page 1 of 3

Case 2:17-cv-02310-APG-NJK Document 27 Filed 04/16/18 Page 2 of 3

1

scheduled to argue Plaintiff’s Motion to Compel the Production of An Unredacted Copy of

2

Defendant’s Claims Notes Pursuant to FRE 612 [ECF No. 18] on April 16, 2018 at 2:00 p.m. Thus,

3
4
5
6

the instant stipulation will allow Plaintiff’s Motion to Compel to be resolved and, if necessary,
additional discovery documents to be produced before Plaintiff’s Opposition would be due so that
Plaintiff would not need to seek relief pursuant to FRCP 56(f). Finally, granting this extension will

7

not require the Court to alter any hearing date on Defendant’s Motion for Summary Judgment as no

8

such hearing date has been set.

9

Based on the foregoing, the Parties hereby stipulate and request that the Court issue an

10

Order extending the deadline for Plaintiff to file his Opposition to Defendant’s Motion for

11
12
13
14

Summary Judgment [ECF No. 24] by no later than April 30, 2018.
IT IS SO STIPULATED.
DATED: April 16, 2018

TYSON & MENDES LLP
By /s/ Carrie McCrea Hanlon
Carrie McCrea Hanlon, Esq. (3902)
3960 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169
Attorneys for Defendant AIG Claims, Inc.

15
16
17
18
19
20
21
22
23

DATED: April 16, 2018

CAMPBELL AND WILLIAMS
By /s/ Samuel R. Mirkovich
Donald J. Campbell, Esq. (1216)
Samuel R. Mirkovich, Esq. (11662)
700 South Seventh Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff

24
25
26
27
28

ORDER
Based on the Stipulation between Plaintiff and Defendant [ECF No. 25], which I treat as a
joint motion under LR 6-1(a), IT IS SO ORDERED.
joint motion under LR 6-1(a), IT IS SO ORDERED.
4/16/2018
_________________________________
UNITED STATES DISTRICT JUDGE

Page 2 of 3