Mendoza v. Amalgamated Transit Union International et al

Filing 48

ORDER Granting 45 Stipulation for Extension of Time re 38 Motion to Dismiss (First Request). Replies due by 1/2/2018. Signed by Judge James C. Mahan on 12/21/2017. (Copies have been distributed pursuant to the NEF - MR)

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CHRISTENSEN JAMES & MARTIN

7440 WEST SAHARA AVE., LAS VEGAS, NEVADA 89117
PH: [phone] § FAX: [phone]

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CHRISTENSEN JAMES & MARTIN
EVAN L. JAMES, ESQ. (7760)
KEVIN B. ARCHIBALD, ESQ. (13817)
7440 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail], [e-mail]

BREDHOFF & KAISER
BRUCE R. LERNER, ESQ. (admitted pro hac vice)
JACOB KARABELL, ESQ. (admitted pro hac vice)
805 15th Street N.W., Suite 1000
Washington, D.C. 20005
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail], [e-mail]
Attorneys for Amalgamated Transit Union International, James
Lindsay III, Lawrence J. Hanley, Antonette Bryant, Terry Richards,
Carolyn Higgins, Keira Mcnett, Daniel Smith, and Tyler Home

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOSE MENDOZA JR., individually and as
a member and on behalf of the
AMALGAMATED TRANSIT UNION
LOCAL 1637, a non-profit corporation,

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Plaintiff,
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vs.

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AMALGAMATED TRANSIT UNION
INTERNATIONAL (“ATU”), a nonprofit
corporation; JAMES LINDSAY III,
individually and in his official capacity as
ATU International Vice President and
Trustee; LAWRENCE J. HANLEY,
individually and in his official capacity as
International Union President;
ANTONETTE BRYANT, individually and
in her official capacity as International
Representative and Hearing Officer;
TERRY RICHARDS, individually;
CAROLYN HIGGINS, individually;
KEIRA MCNETT, individual; DANIEL
SMITH, individually; TYLER HOME,
individually; DOES; and ROE
CORPORATIONS 1-20, inclusive,

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Defendants.

CASE NO.: 2:17-cv-02485-JCM-CWH
STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE REPLY
IN SUPPORT OF DEFENDANTS’
MOTION TO DISMISS

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Defendants Amalgamated Transit Union et al., by and through their counsel of record,

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Evan L. James, Esq.; and Plaintiff Jose Mendoza, by and through his counsel of record, Michael

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Mcavoyamaya, Esq., stipulate and agree as follows:

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Whereas a Motion To Dismiss was filed by Defendants on December 5, 2017 (ECF No.
38).
Whereas Plaintiff will file an Opposition to Defendants’ Motion to Dismiss on December

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19, 2017.

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Whereas the deadline for Defendants to file a Reply in support of their Motion to Dismiss
is December 26, 2017.
Whereas to accommodate pre-planned holiday travel that counsel for Defendants has, the

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parties have agreed to extend the deadline for Defendants to file their Reply in support of their

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Motion to Dismiss to January 2, 2018.

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It Is Hereby Stipulated that the deadline for Defendants to file their Reply in support of

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their Motion to Dismiss be extended from December 26, 2017 to January 2, 2018.1

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SO STIPULATED

SO STIPULATED

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DATED this 19th day of December, 2017.

DATED this 19th day of December, 2017.

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MICHAEL J. MCAVOYAMAYA, ESQ.
By: /s/ Michael J. Mcavoyamaya
Michael J. Mcavoyamaya, Esq.
Nevada Bar No.: 14082
4539 Paseo Del Ray
Las Vegas, NY 89121
Counsel for Plaintiff’

CHRISTENSEN JAMES & MARTIN
By: /s/ Evan L. James
Nevada Bar No. 7760
7440 W. Sahara Avenue
Las Vegas, NV 89117

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BREDHOFF & KAISER, P.L.L.C

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By: /s/ Jacob Karabell
admitted pro hac vice
805 15th Street N.W., Suite 1000
Washington, DC 20005
Counsel for Defendants

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IT IS SO ORDERED:

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____________________________________
UNITED STATES DISTRICT JUDGE

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December 21, 2017.
DATED: _____________________________

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Should the Court wish to set oral argument on Defendants’ Motion to Dismiss, Plaintiffs’
counsel would like to inform the Court that he will be out of the country from January 5 through
January 15, 2008.
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