Mahdi v. American Airlines, Inc. et al

Filing 57

ORDER Granting 56 Stipulation to Extend Time Re: 50 Motion to Dismiss, 51 Motion for Judgment. Replies due by 11/14/2018. Signed by Judge Richard F. Boulware, II on 11/8/2018. (Copies have been distributed pursuant to the NEF - ADR)

1
2
3
4
5
6
7
8
9
10

PAUL E. BATEMAN, ESQ., BAR # 6188371 (Pro Hac Vice)
LITTLER MENDELSON, P.C.
321 North Clark Street, Suite 1000
Chicago, IL 60654
Telephone:
312.372.5520
Fax No.:
312.372.7880
E-mail:
[e-mail]
KATHRYN BLAKEY, ESQ., BAR # 12701
LITTLER MENDELSON, P.C.
2001 Ross Avenue
Suite 1500, Lock Box 116
Telephone: [phone]
Fax No.:
214.880.0181
E-mail:
[e-mail]
Attorneys for Defendants
AMERICAN AIRLINES, INC. AND
AMERICAN AIRLINES GROUP, INC.

11

UNITED STATES DISTRICT COURT

12

DISTRICT OF NEVADA

13
14

MAHMUD MAHDI,
Plaintiff,

15
16

vs.

17

AMERICAN AIRLINES, INC., a foreign
corporation; AMERICAN AIRLINES
GROUP, INC., a foreign corporation;
DOES and ROES 1-100, inclusive,

18
19
20
21

Defendants.

Case No. 2:17-cv-02853-RFB-GWF
STIPULATION AND PROPOSED ORDER
TO EXTEND THE DEADLINE FOR
DEFENDANTS TO FILE A REPLY IN
SUPPORT OF ITS PARTIAL MOTION TO
DISMISS [ECF NO. 50] AND REPLY IN
SUPPORT OF ITS MOTION FOR
PARTIAL JUDGMENT ON THE
PLEADINGS [ECF NO. 51]
(FIRST REQUEST)

22
23

Plaintiff MAHMUD MAHDI (“Plaintiff”) and Defendants AMERICAN AIRLINES INC.

24

and AMERICAN AIRLINES GROUP, INC., (“Defendants”), by and through their attorneys of

25

record, stipulate to extend the deadline for Defendants to File a Reply in Support of its Motion for

26

Partial Dismissal of Plaintiff’s First Amended Complaint (Claim 4) Pursuant to FRCP 12(b)(1) and

27

12(h)(3) [ECF No. 50], and its Motion for Partial Judgment on the Pleadings (Claims 4, 5 and 6)

28

Pursuant to FRCP 12(c) [ECF No. 51] to up to and including November 14, 2018.

LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

1

///

2

This is the first extension of Defendants’ deadline to file a reply in support of its partial

3

motion to dismiss and to file a reply in support of its motion for judgment on the pleadings and is

4

made in good faith by stipulation of the parties. This extension is needed due to Defense counsel’s

5

current work load which has included depositions, dispositive motions, and previously scheduled

6

court deadlines which have limited the ability to communicate with Defendants. Accordingly, in

7

order to provide a full and proper substantive reply to Plaintiff’s Oppositions, the requested one-

8

week extension to up to and including November 14, 2018, is necessary.

9

Dated: November 7, 2018

10

Respectfully submitted,

11
12
13

/s/ Sharon L. Nelson, Esq.
SHARON L. NELSON
NELSON LAW

14

Attorneys for Plaintiff

15

/s/ Kathryn B. Blakey, Esq.
PAUL BATEMAN
KATHRYN B. BLAKEY
LITTLER MENDELSON, P.C.
Attorneys for Defendants

16

IT IS SO ORDERED.

17

8th
Dated this ___ Day of November, 2018.

18
19

__________________________________________
UNITED STATES DISTRICT JUDGE

20
21
22
23
24
25
26
27
28
LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

FIRMWIDE:159902907.1 086761.1028

2.