Klatt v. Dignity Health

Filing 100

ORDER Granting 99 Stipulation for Extension of Time re 98 Order (Fourth Request). Settlement documents are due by 7/26/2019. Signed by Magistrate Judge Brenda Weksler on 7/22/2019. (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 of Case No. 2:17-cv-02425-RFB-BNW
herself and all others similarly situated;
STIPULATION AND ORDER TO
CONTINUE SETTLEMENT
Plaintiff,
DOCUMENTS DEADLINE
v.
(Fourth Request)
DIGNITY HEALTH, a California corporation;
DOES 1-50, unknown individuals; and ROE
COMPANIES 1-50, unknown business entities,

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Defendants.

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Plaintiff Megan Klatt (“Plaintiff”), by and through her attorneys of record, and Defendant

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Dignity Health (“Defendant”) (collectively, the “Parties”), by and through its attorneys of record,

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submit this Stipulation and Order to Continue Settlement Documents Deadline (Fourth Request)

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(the “Stipulation”).

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On February 28, 2019, the Parties participated in a mediation and subsequently reached a

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settlement in principal. Therefore, on April 5, 2019, the Parties submitted a Stipulation and Order

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to Suspend Dispositive Motion Deadlines Pending Settlement (“Stipulation to Suspend”),

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requesting that the dispositive motion deadlines be suspended while the Parties worked diligently

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to draft and agree upon the requisite settlement documents, ECF No. 86.

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Case 2:17-cv-02425-RFB-BNW Document 99 Filed 07/19/19 Page 2 of 3

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On April 10, 2019, the Court issued an Order granting the Stipulation to Suspend and

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directed the Parties to file a stipulation to dismiss or dispositive motions by May 17, 2019, ECF

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No. 87.

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On May 16, 2019, the Parties filed a Stipulation and Order to Continue Settlement

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Documents Deadline (First Request), ECF No. 89, which the Court granted on May 17, 2019, ECF

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No. 93, because they needed additional time to complete the drafting of the settlement documents

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given the complexity of the issues and length of documents, including a Joint Motion for

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Preliminary Approval of Class Action Settlement and the associated Joint Stipulation of Settlement,

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as well as various documents to be provided to the putative class members, which will require Court

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approval.

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

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On July 1, 2019, the Parties filed a Stipulation and Order to Continue Settlement Documents

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Deadline (Second Request), ECF No. 95, which the Court granted on July 3, 2019, ECF No. 96,

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because they needed additional time to complete the drafting of the settlement documents. The

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settlement papers are currently due on July 10, 2019, ECF No. 96.

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On July 10, 2019, the Parties filed a Stipulation and Order to Continue Settlement

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Documents Deadline (Third Request), ECF No. 97, which the Court granted on July 11, 2019, ECF

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No. 98, because they needed additional time to complete the drafting of the settlement documents.

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The settlement papers are currently due on July 19, 2019, ECF No. 98.

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Since the last extension was granted, the Parties have continued to work diligently to finalize

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the settlement papers and have discussed additional changes to the settlement papers, but have been

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unable to finalize the documents in light of counsel for Plaintiff being out of the office traveling on

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vacation. As such, the Parties request an additional seven (7) days, through and including July 26,

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2019, to complete the documents and submit the papers for Court approval.

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This Stipulation is submitted in good faith and not for the purpose of delay.

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Dated this 19th day of July 2019.

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SEMENZA KIRCHER RICKARD

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/s/ Lawrence J. Semenza, III, Esq.
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
Attorneys for Plaintiff Megan E.
Klatt and all others similarly situated

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Dated this 19th day of July 2019.

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/ Kristen A. Milton Esq.
Elayna J. Youchah, Esq., Bar No. 5837
Kirsten A. Milton, Esq., Bar No. 14401
3800 Howard Hughes Parkway, Suite
600 Las Vegas, Nevada 89169
Attorneys for Defendant Dignity Health

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IT IS SO ORDERED.
__________________________________
UNITED STATES MAGISTRATE JUDGE
DATED this 22nd day of July 2019.

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