Klatt v. Dignity Health

Filing 55

ORDER Granting 52 Stipulation to Amend Briefing Schedule re 40 Motion for Protective Order. The 51 First Stipulation to Set Briefing Scheduling is DENIED as moot. The Court shall hear oral argument on unresolved issues presented in Defendant's Motion for Protective Order on 8/14/2018, at 11:00 am. Signed by Magistrate Judge Peggy A. Leen on 7/10/2018. (Copies have been distributed pursuant to the NEF - MR)

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

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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
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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 TO
AMEND BRIEFING
Plaintiff,
SCHEDULE ON MOTION FOR
PROTECTIVE ORDER
v.
DIGNITY
HEALTH,
a
California
corporation;
DOES
1-50,
unknown
individuals; and ROE COMPANIES 1-50,
unknown business entities,

(Second Request)

Defendants.
Megan Klatt, Plaintiff, and Dignity Health, Defendant (collectively, the “Parties”), by and
through their respective counsel, previously stipulated and agreed that by end of day June 22, 2018,
they would provide the Court with the status of efforts to resolve issues first identified in
Defendant’s Motion for Protective Order (ECF No. 40) (“Defendant’s Motion”), which arise from
Plaintiff’s 30(b)(6) Deposition Notice. The Parties subsequently requested a two week extension
of time to provide the Court information on these efforts. (ECF No. 50). The Parties filed a
Stipulation to Set Briefing Schedule on the Motion for Protective Order (ECF No. 51) on June 22,
2018. The Court has not yet ruled on the submitted Stipulation.

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The Parties are still working diligently to resolve all their differences; however, not all issues

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raised in Defendant’s Motion have been resolved. Hence, the Parties request the Court enter the

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following briefing schedule for purposes:

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1.

Plaintiff’s Opposition to Defendant’s Motion shall be filed by or before July 9, 2018;

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2.

Defendant’s Reply in Support of Defendant’s Motion shall be filed by or before July

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23, 2018; and,
3.

The Court set a hearing to consider the unresolved issues presented in Defendant’s

Motion as soon as practicable.
This stipulation is submitted in good faith and not for the purpose of delay.
Dated this 5th day of July 2018.

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

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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

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

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Dated this 5th day of July 2018.
JACKSON LEWIS P.C.
/s/ Kirsten 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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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) be as follows:

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1.

Plaintiff’s Opposition to Defendant’s Motion shall be filed by or before July 9, 2018;

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2.

Defendant’s Reply in Support of Defendant’s Motion shall be filed by or July 23,

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

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2018; and,
3.

The Court shall hear oral argument on unresolved issues presented in Defendant’s

Motion for Protective Order on the 14th day of August, 2018, at 11:00 am.
4.

The Second Stipulation (ECF No. 52) is GRANTED.

5.

The First Stipulation (ECF No. 51) is DENIED as moot.

IT IS SO ORDERED:
____________________________________________
UNITED STATES MAGISTRATE JUDGE

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DATED: July 10, 2018

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