Klatt v. Dignity Health

Filing 10

ORDER Granting 9 Stipulation for Extension of Time re 4 Motion to Dismiss (Second Request). Responses due by 10/25/2017. Signed by Judge Richard F. Boulware, II on 10/24/17. (Copies have been distributed pursuant to the NEF - MR)

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Lawrence J. Semenza, III, Esq., Bar No. 7174
Email: [e-mail]
Christopher D. Kircher, Esq., Bar No. 11176
Email: [e-mail]
Jarrod L. Rickard, Esq., Bar No. 10203
Email [e-mail]
SEMENZA KIRCHER RICKARD
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Megan E. Klatt
and all others similarly situated

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

SEMENZA KIRCHER RICKARD
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]

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MEGAN E. KLATT, an individual, on behalf Case No. 2:17-cv-02425-RFB-PAL
of herself and all others similarly situated;
STIPULATION AND ORDER
CONTINUING DEADLINE FOR
Plaintiff,
PLAINTIFF'S OPPOSITION TO
DEFENDANT'S MOTION TO DISMISS
v.
PARTS OF PLAINTIFF'S COMPLAINT
DIGNITY
HEALTH,
a
California
(Second Request)
corporation;
DOES
1-50,
unknown
individuals; and ROE COMPANIES 1-50,
unknown business entities,
Defendants.

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Plaintiff Megan E. Klatt ("Plaintiff") and Defendant Dignity Health ("Defendant"), by and
through their respective counsel of record, hereby submit this second stipulation to extend the

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time for Plaintiff to file its Opposition to Defendant's Motion to Dismiss Parts of Plaintiff's

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Complaint (the "Motion") (Dkt. 4).

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BACKGROUND

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A.

On September 25, 2017, Defendant filed the Motion.

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B.

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On October 5, 2017, the Court granted the Parties' stipulated Order continuing the

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deadline for Plaintiff's Opposition to the Motion from October 9, 2017, to October 23, 2017, and

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continuing the deadline for Defendant's Reply in Support of the Motion to November 13, 207.
C.

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While Plaintiff had anticipated being able to file the Opposition by October 23,

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2017, conflicts have arisen that necessitate this additional extension. In particular, Plaintiff

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requires additional time to prepare the Opposition as Plaintiff's counsel is still working toward

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upcoming briefing deadlines in two separate appeals pending before the Nevada Supreme Court.

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In light of this, Defendant has agreed to Plaintiff's request for an additional two-day continuation

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of the deadline for the Opposition.

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D.

SEMENZA KIRCHER RICKARD
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]

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A hearing on the Motion has not yet been set.
STIPULATION

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NOW THEREFORE, the parties hereby agree and stipulate as follows:

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1.

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The deadline for Plaintiff's Opposition to the Motion shall be continued to October

25, 2017; and
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2.

The deadline for Defendant's Reply to Plaintiff's Opposition shall remain as

November 13, 2017.
DATED this 23rd day of October 2017.

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SEMENZA KIRCHER RICKARD

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/s/ Jarrod L. Rickard
Lawrence J. Semenza, III, Esq., Bar No. 7174
Christopher D. Kircher, Esq., Bar No. 11176
Jarrod L. Rickard, Esq., Bar No. 10203
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145

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Attorneys for Plaintiff Megan E. Klatt
and all others similarly situated

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SEMENZA KIRCHER RICKARD
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Telephone: [phone]

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JACKSON LEWIS P.C.

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/s/ Elayna J. Youchah
Elayna J. Youchah, Esq., Bar No. 5837
Kirsten A. Milton, Esq., Bar No. 14401
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169

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Attorneys for Defendant Dignity Health

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IT IS SO ORDERED.
__________________________________
UNITED STATES DISTRICT JUDGE

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24th
DATED this _______ day of October 2017.

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