Klatt v. Dignity Health

Filing 46

ORDER Granting 45 Stipulation to Stay Briefing Scheduling re 40 Motion for Protective Order (First Request). See Order for details/deadlines. Signed by Magistrate Judge Peggy A. Leen on 5/18/2018. (Copies have been distributed pursuant to the NEF - MR)

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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]
[e-mail]
[e-mail]
Attorneys for Defendant
Dignity Health

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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

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

Case No. 2:17-cv-02425-RFB-PAL
STIPULATION TO STAY BRIEFING
SCHEDULING ON MOTION FOR
PROTECTIVE ORDER
(First Request)

Defendants.

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Megan Klatt, Plaintiff, and Dignity Health, Defendant (collectively Plaintiff and Defendant

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are referred to herein as the “Parties”), by and through their respective undersigned counsel,

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stipulate and agree to stay briefing in and the Court’s consideration of Defendant’s Motion for

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Protective Order (ECF No. 40) (“Defendant’s Motion”), for a three week period measured from

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May 18, 2018, which is the due date for Plaintiff’s Opposition. The three week stay is requested to

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allow the Parties to continue discussions toward the goal of eliminating the need for the Court to

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consider Defendant’s Motion. At the conclusion of the stay, the Parties shall submit a stipulation

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notifying the Court of one of the following: (i) the Parties have reached agreement regarding the

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issues raised in Defendant’s Motion rendering Defendant’s Motion moot; (ii) the Parties have not

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Jackson Lewis P.C.
Las Vegas

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reached agreement regarding the issues raised in Defendant’s Motion resulting in an agreed upon

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briefing schedule pertaining to all unresolved issues; or (iii) the Parties seek additional time to

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resolve the issues presented in Defendant’s Motion.

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On May 16, 2018 the Court issued a minute order scheduling a hearing on the Defendant’s

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Motion for June 12, 2018 at 10:00 a.m. Given the agreement of the Parties as set forth above, it is

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requested that the Court vacate the scheduled hearing.

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

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DATED this 17th day of May 2018.

DATED this 17th day of May 2018.

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SEMENZA KIRCHER RICKARD

JACKSON LEWIS P.C.

/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

/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

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

Attorneys for Defendant Dignity Health

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ORDER

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IT IS HEREBY ORDERED THAT, the briefing schedule and the Court’s consideration of
Defendant, Dignity Health’s Motion for Protective Order (ECF No. 40) shall be stayed through and
including June 12. On or before the end of the day on June 8, Plaintiff and Defendant shall submit
a stipulation notifying Court that (i) identifies whether ECF No.40 is moot, (ii) provides the Court
with a revised briefing schedule on remaining issues presented in Defendant’s Motion, or (iii)
explains the need for more time to resolve issues addressed by ECF No. 40.
The hearing presently scheduled for June 12, 2018 relating to Defendant's Motion shall be
vacated.

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____________________________________
UNITED STATES MAGISTRATE JUDGE

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Jackson Lewis P.C.
Las Vegas

DATED:
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May 18, 2018