Klatt v. Dignity Health

Filing 93

ORDER Granting 89 Stipulation for Extension of Time to File Settlement Documents re 87 Order (First Request). Settlement documents are due by 7/1/2019. Signed by Magistrate Judge Brenda Weksler on 5/17/2019. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6
7
8
9

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]
Katie L. Cannata, Esq., Bar No. 14848
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

10
UNITED STATES DISTRICT COURT

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

11

DISTRICT OF NEVADA

12
13

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

14
15

Plaintiff,

STIPULATION AND ORDER TO
CONTINUE SETTLEMENT
DOCUMENTS DEADLINE

v.

16
17
18

Case No.: 2:17-cv-02425-RFB-BNW

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

19
Defendants.

20
21

Plaintiff Megan E. Klatt and all others similarly situated ("Klatt") and Dignity Health

22

("Dignity") (collectively, the "Parties"), by and through their respective counsel of record, hereby

23

submit this Stipulation and Order to Continue Settlement Documents Deadline (the "Stipulation").

24

On February 28, 2019, the Parties attended mediation and subsequently reached a settlement

25

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

26

Dispositive Motion Deadlines Pending Settlement ("Stipulation to Suspend"), requesting that the

27

dispositive motion deadlines be suspended while the Parties worked diligently to draft and agree

28

upon the requisite settlement documents.

1

1

Given the Parties' settlement, on April 10, 2019, the Court issued an Order Granting the

2

Stipulation to Suspend and directed the Parties to file a stipulation to dismiss or dispositive motions

3

by May 17, 2019.

4

The Parties are currently in the process of finalizing a host of complex and lengthy

5

settlement documents, including a Joint Motion for Preliminary Approval of Class Action

6

Settlement and the associated Joint Stipulation of Settlement, which will require Court approval.

7

As such, the Parties respectfully request an additional forty-five (45) days to submit the necessary

8

settlement documents, up to and including July 1, 2019.

9
10

This Stipulation is submitted in good faith and not for the purpose of delay.
Dated this 16th day of May, 2019.

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

11

SEMENZA KIRCHER RICKARD

12

/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
Katie L. Cannata, Esq., Bar No. 14848
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145

13
14
15
16

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

17
18

Dated this 16th day of May, 2019.

19
JACKSON LEWIS, P.C.

20
/s/ Kristen A. Milton
Kristen A. Milton, Esq., Bar No. 14401
3800 Howard Hughes Parkway, Suite 600
Las Vegas, Nevada 89169

21
22
23

Attorneys for Defendant Dignity Health

24
25
26
27
28

IT IS SO ORDERED.
_____________________________________________
UNITED STATES MAGISTRATE JUDGE
May 17, 2019
DATED: _______________________

2