Klatt v. Dignity Health

Filing 26

ORDER Granting 25 Stipulation To Set Briefing Scheduling re 24 Motion for Partial Summary Judgment. Responses due by 3/19/2018. Replies due by 4/16/2018. Signed by Judge Richard F. Boulware, II on 2/28/2018. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6
7

Elayna J. Youchah
Nevada State Bar No. 5837
Kirsten A. Milton
Nevada State Bar. No. 14401
JACKSON LEWIS P.C.
3800 Howard Hughes Pkwy, Suite 600
Las Vegas, Nevada 89169
Tel: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
Dignity Health

8
9

UNITED STATES DISTRICT COURT

10
11
12

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

13
14
15
16
17

vs.

Case No. 2:17-cv-02425-RFB-PAL
STIPULATION TO SET BRIEFING
SCHEDULE FOR MOTION FOR
PARTIAL SUMMARY JUDGMENT

DIGNITY HEALTH, a California corporation;
DOES 1-50, unknown individuals; and ROE
COMPANIES 1-50, unknown business
entities,
Defendants.

18
19

Plaintiff Megan E. Klatt ("Plaintiff") and Defendant Dignity Health ("Defendant"), by and

20

through their respective counsels of record, submit this stipulation setting a briefing schedule

21

arising from Plaintiff’s Motion for Partial Summary Judgment (“Plaintiff’s Motion”) filed on

22

February 12. 2018.

23

After consulting regarding defense counsel’s availability, which includes out of state travel,

24

multiple depositions, and discovery in other cases, all of which was calendared before Plaintiff’s

25

Motion was filed, the parties agree to the following briefing schedule for Defendant’s Opposition

26

to Plaintiff’s Motion, and Plaintiff’s Reply in support thereof. Specifically, Defendant shall have

27

through and including March 19, 2018 to file its Opposition to Plaintiff’s Motion. Plaintiff shall

28

have through and including April 16, 2018 to file her Reply.

Jackson Lewis P.C.
Las Vegas

STIPULATION

1
2

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

3

The deadline for Defendant to file its Opposition to Plaintiff’s Motion shall be through and

4
5
6

including March 19, 2018.
The deadline for Plaintiff to file her Reply in Support of her Motion shall be through and
including April 16, 2018.

7

This stipulation is offered in good faith and not for purposes of delay.

8

DATED this 27th day of February, 2018.

9
10
11
12
13
14
15

SEMENZA KIRCHER RICKARD
/s/ Lawrence J. Semenza III
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

16
17

JACKSON LEWIS P.C.

20

/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

21

Attorneys for Defendant Dignity Health

18
19

22
23

IT IS SO ORDERED:

24
25
26

UNITED STATES MAGISTRATE JUDGE
DATED:

27
28
Jackson Lewis P.C.
Las Vegas

2

28th day of February, 2018.