Fleming v. CIGNA Healthcare

Filing 23

ORDER Granting 20 Stipulation Re: 11 Motion to Dismiss. IT IS SO ORDERED that the Opposition to the Defendant's PartialMotion to Dismiss shall be due on 2/22/18. IT IS SO ORDERED that the Reply to the Opposition to the Defendant's Partial Motion to Dismiss shall be due on 3/8/18. IT IS SO ORDERED that the 2/23/18, hearing is VACATED and continued to MONDAY, 3/12/18, at 2 p.m. Signed by Judge Jennifer A. Dorsey on 2/8/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-03049-JAD-CWH Document 20 Filed 02/07/18 Page 1 of 3

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JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
HKM EMPLOYMENT ATTORNEYS LLP
1785 E. Sahara Ave, Suite 325
Las Vegas, NV 89104
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorney for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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CATHERINE FLEMING, An Individual
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Plaintiff,

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vs.
CIGNA HEALTHCARE, DOES I-X;
ROE CORPORATIONS I-X.
Defendants.

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) CASE NO. 2:17-cv-03049-JAD-CWH
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ECF NO. 20
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STIPULATION AND ORDER TO EXTEND THE TIME TO RESPOND TO
DEFENDANT’S PARTIAL MOTION TO DISMISS
(FIRST REQUEST)

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COMES NOW, the Plaintiff, CATHERINE FLEMING (“Fleming”), by and through

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her attorney, JENNY L. FOLEY, Ph.D., ESQ., of the law firm HKM EMPLOYMENT

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ATTORNEYS LLP, and Defendant, CIGNA HEALTHCARE (“CIGNA”), by and through its

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attorneys, WENDY MEDURA KRINCEK, ESQ., and KAITLYN M. BURKE, ESQ., of

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LITTLER MENDELSON, P.C., hereby stipulate and agree as follows:
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That the Opposition to the Defendant’s Partial Motion to Dismiss due on

February 8, 2018, may be due on February 22nd, 2018.
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That the Reply to the Opposition to the Defendant’s Partial Motion to Dismiss

be due on March 8, 2018.

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Page 1 of 3

Case 2:17-cv-03049-JAD-CWH Document 20 Filed 02/07/18 Page 2 of 3

3.

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The parties request that the hearing be continued to a date after March 8, 2018,

or as soon thereafter as the Court may hear the matter.

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4.

This extension of time is made in good faith and not for purposed of delay. The

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parties have requested this extension of time due to counsels’ respective other pre-existing
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calendar commitments.
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This is the first request for an extension of time in this matter.

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Dated this __7th_ day of February, 2018.

Dated this __7th___ day of February,

2018.

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HKM Employment Attorneys LLP

/s/ Jenny L. Foley
Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave., Suite 325
Las Vegas, Nevada 89104

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Littler Mendelson, P.C.

____/s/ Kaitlyn M. Burke_________
Wendy Medura Krincek, Esq.
Kaitlyn M. Burke, Esq.
Nevada Bar No. 6417
Nevada Bar No. 13454
3960 Howard Hughes Parkway
Suite 300
Las Vegas, Nevada 89169

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Case 2:17-cv-03049-JAD-CWH Document 20 Filed 02/07/18 Page 3 of 3

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ORDER
The Court having reviewed the foregoing STIPULATION AND ORDER TO EXTEND
THE TIME TO RESPOND TO DEFENDANT’S PARTIAL MOTION TO DISMISS in the

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above-entitled matter and for good cause appearing therefor,
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IT IS SO ORDERED that the Opposition to the Defendant’s Partial Motion to Dismiss
shall be due on February 22nd, 2018;
IT IS SO ORDERED that the Reply to the Opposition to the Defendant’s Partial
Motion to Dismiss shall be due on March 8, 2018;
the February 23, 2018, hearing is continued to after March
IT IS SO ORDERED that the hearing on this matter shall beVACATED and continued
8, 2018. The new hearing date will p.m.
to MONDAY, March 12, 2018, at 2be

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a.m / p.m.

_______________________________
U.S. District Judge Jennifer A. Dorsey
February 8, 2018

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2018 at

Dated:

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UNITED STATES MAGISTRATE JUDGE

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Respectfully submitted by:
HKM Employment Attorneys LLP

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/s/ Jenny L. Foley
Jenny L. Foley, Ph.D., Esq.
Nevada Bar No. 9017
1785 East Sahara Ave, Suite 325
Las Vegas, Nevada 89104
Attorney for Plaintiff

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