U.S. Equal Employment Opportunity Commission v. Lucinda Management, LLC et al

Filing 17

ORDER granting ECF No. 16 Stipulation to Extend Time to Answer or Otherwise Respond to Complaint. Answer/response due 01/08/2018. Plaintiff may file a response to any motion responsive to complaint by 02/12/2018. Signed by Magistrate Judge George Foley, Jr on 12/12/2017. (Copies have been distributed pursuant to the NEF - KW)

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RICHARD I. DREITZER, ESQ.
Nevada Bar No. 6626
JAMES T. TUCKER, ESQ.
Nevada Bar No. 12507
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
300 South Fourth Street, Eleventh Floor
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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U.S. EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION,
Plaintiff,

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v.

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CASE NO: 2:17-cv-02458-MMD-GWF
STIPULATION AND ORDER TO EXTEND
TIME TO ANSWER OR OTHERWISE
RESPOND TO COMPLAINT

LUCINDA MANAGEMENT, LLC, et al.,

(First Request)

Defendants.

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Plaintiff U.S. Equal Employment Opportunity Commission, (hereinafter “Plaintiff”) by and

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through undersigned counsel, and Defendants Lucinda Management, LLC, et al. ( “Defendants”), by

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and through undersigned counsel, hereby stipulate and agree that: (1) the time in which Defendants

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may answer or otherwise respond (e.g. file a responsive pleading or motion) to the Complaint be

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extended until January 8, 2018; and (2) the time in which the Plaintiff may file its response to any

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motion responsive to the Complaint that may be filed by Defendants be extended until February 12,

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2018.

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The Plaintiff’s Complaint asserts sexual harassment and retaliation claims against nearly a

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dozen companies in Nevada and New York on behalf of three named plaintiffs and a class of

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claimants with allegations dating back as much as fifteen years. Given the scope of the allegations

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and size of the proposed class (as identified by the Plaintiff during previous communications),

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Defendants require additional time to prepare a pleading or motion responsive to the Complaint.
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The Parties further mutually agree that the requested deadlines will avoid conflicts with the holiday

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season, including office closures and previously scheduled vacations. As such, good cause is

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provided for this request. In making this stipulation, the Parties each do not waive any of their

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respective legal or procedural rights, which are hereby preserved.

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Dated this 11th day of December, 2017.

Dated this 11th day of December, 2017.

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U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

/s/ Nechole M. Garcia
__________________________________
NECHOLE M. GARCIA
Nevada Bar No. 12746
333 Las Vegas Boulevard South, Suite 8112
Las Vegas, NV 89101
[phone]
Attorneys for Plaintiff

/s/ Richard I. Dreitzer
__________________________________
RICHARD I. DREITZER
Nevada Bar No.: 6626
JAMES T. TUCKER
Nevada Bar No.: 12507
300 South 4th Street, 11th Floor
Las Vegas, NV 89101
[phone]
Attorneys for Defendants

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ORDER
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UPON STIPULATION OF THE PARTIES AND FOR GOOD CAUSE SHOWN, it is
hereby ordered and adjudged:
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The time in which Defendants may answer or otherwise respond (file a responsive

pleading or motion) to the Complaint shall be extended until January 8, 2018;
2.

The time in which the Plaintiff may file its response to any motion responsive to the

Complaint that may be filed by Defendants shall be extended until February 12, 2018; and

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3.

The Parties’ respective legal or procedural rights are hereby preserved.

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IT IS SO ORDERED.
Dated: 12/12/2017

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UNITED SATES MAGISTRATE JUDGE

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