Klatt v. Dignity Health

Filing 102

ORDER Granting 101 Stipulation for Extension of Time re 100 Order (Fifth Request). Settlement documents are due by 8/2/2019. Signed by Magistrate Judge Brenda Weksler on 7/30/2019. (Copies have been distributed pursuant to the NEF - MR)

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Kirsten A. Milton, Bar No. 14401
Daniel Aquino, Bar No. 12682
JACKSON LEWIS P.C.
300 South Fourth Street, Suite 900
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
Attorneys for Defendant
Dignity Health
Lawrence J. Semenza, III, Bar No. 7174
Christopher D. Kircher, Bar No. 11176
Jarrod L. Rickard, Bar No. 10203
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145
Attorneys for Plaintiff
Megan Klatt, on behalf of herself
and all others similarly situated

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
MEGAN KLATT, an individual, on behalf
of herself and all others similarly situated,
Plaintiff,

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JACKSON LEWIS P.C.
LAS VEGAS

vs.

Case No.: 2:17-cv-02425-RFB-BNW
STIPULATION AND ORDER TO
CONTINUE SETTLEMENT
DOCUMENTS DEADLINE (Fifth Request)

DIGNITY HEALTH, a California
corporation; DOES 1-50, unknown
individuals; and ROE COMPANIES 1-50,
unknown business entities,
Defendants.
Plaintiff Megan Klatt (“Plaintiff”), by and through her attorneys of record, and Defendant
Dignity Health (“Defendant”) (collectively, the “Parties”), by and through its attorneys of record,
submit this Stipulation and Order to Continue Settlement Documents Deadline (Fifth Request)
(the “Stipulation”).
On February 28, 2019, the Parties participated in a mediation and subsequently reached a
settlement in principal. Therefore, on April 5, 2019, the Parties submitted a Stipulation and Order
to Suspend Dispositive Motion Deadlines Pending Settlement (“Stipulation to Suspend”),

Case 2:17-cv-02425-RFB-BNW Document 101 Filed 07/26/19 Page 2 of 3

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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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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,

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

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

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

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

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require Court approval.

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

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

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ECF No. 96, because they needed additional time to complete the drafting of the settlement

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

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On July 19, 2019, the Parties filed a Stipulation and Order to Continue Settlement

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Documents Deadline (Fourth Request), ECF No. 99, which the Court granted on July 22, 2019,

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ECF No. 100, because they needed additional time to complete the drafting of the settlement

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documents as Plaintiff’s counsel was out of the office traveling. The settlement papers are

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currently due on July 26, 2019, ECF No. 100.

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JACKSON LEWIS P.C.
LAS VEGAS

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

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finalize the settlement papers and are hopeful that they have agreement on all substantive issues.

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However, they still also need to secure the signatures of the respective parties. As such, the

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Parties request an additional seven (7) days, through and including August 2, 2019, to get the

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documents executed 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: July 26th, 2019

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

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Attorneys for Plaintiff, on behalf of
herself and all others similarly situated

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DATED: July 26th, 2019

JACKSON LEWIS P.C.

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/s/ Kirsten A. Milton
Kirsten A. Milton, Bar No. 14401
Daniel I. Aquino, Bar No. 12682
300 S. Fourth Street, Suite 900
Las Vegas, NV 89101

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Attorneys for Defendant
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IT IS SO ORDERED.
__________________________________
UNITED STATES MAGISTRATE JUDGE
DATED this 30th day of July 2019.

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JACKSON LEWIS P.C.
LAS VEGAS

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