Whittier v. Ceasars Entertainment Corporation

Filing 12

ORDER Granting 11 Stipulation to Reschedule Early Neutral Evaluation Session. The Early Neutral Evaluation session scheduled for 3/13/18 is VACATED and RESCHEDULED to 4/6/18 at 10:00 AM. The ENE confidential statement is due by 4:00 PM, 3/30/18. All else as stated in 9 the Order setting the ENE remains unchanged. Signed by Magistrate Judge Cam Ferenbach on 2/26/2018. (Copies have been distributed pursuant to the NEF - ADR)

1
2
3
4
5
6
7
8

PATRICK H. HICKS, ESQ., Bar # 4632
SANDRA KETNER, ESQ., Bar # 8527
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
CAESARS ENTERPRISE SERVICES, LLC (incorrectly named as
"CAESARS ENTERTAINMENT CORPORATION")
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11

TERRENCE WHITTIER, an individual;

12

Plaintiff,

13

vs.

14

CAESARS ENTERTAINMENT
CORPORATION, a Foreign Corporation,
dba CAESARS ENTERTAINMENT, LAS
VEGAS; DOES I-X, ROE
CORPORATIONS I-X.

15
16
17

Case No. 2:18-00213-GMN-CWH
STIPULATION TO RESCHEDULE
EARLY NEUTRAL EVALUATION
SESSION
[FIRST REQUEST]

Defendants.

18
19

Plaintiff TERRENCE WHITTIER (“Plaintiff”) and Defendant CAESARS ENTERPRISE

20

SERVICES, LLC (incorrectly named as “CAESARS ENTERTAINMENT CORPORATION” and

21

hereinafter referred to as “Defendant”), by and through their respective counsel, do hereby stipulate

22

and request that the Early Neutral Evaluation (“ENE”) session currently scheduled for March 13,

23

2018, be rescheduled to a later date for the reasons set forth herein.

24

Counsel for the parties are currently engaged in discussions regarding potential legal

25

deficiencies in the claims asserted in Plaintiff’s Complaint (ECF No. 1). Counsel believes that such

26

discussions will likely result in Plaintiff filing an amended complaint before Defendant files its

27

responsive pleading. Defendant’s first responsive pleading is not due until March 14, 2018, the day

28

after the currently scheduled ENE. (ECF No. 10). Therefore, the parties will not likely be fully

LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
200 S. Virginia St.
8th Floor
Reno, NV 89501
775.348.4888

Firmwide:153052335.1 079206.1009

1

apprised of and have an opportunity to analyze the claims and defenses of the opposing party at the

2

time of the currently scheduled ENE (or the date that the parties’ ENE Statements are due).

3

The parties believe that they will be unable to engage in meaningful settlement discussions if

4

the ENE is held on March 14, 2018. Therefore, the parties request that the ENE be rescheduled for a

5

date after April 5, 2018. If the Court is inclined to reschedule the ENE, the parties suggest that they

6

be ordered to contact chambers to obtain available dates in April for the ENE. This Stipulation is

7

made in good faith and not for purposes of delay.

8

Dated: February 23, 2018

February 23, 2018

9
10
11
12
13

/s/Jenny L. Foley
JENNY L. FOLEY, Ph.D., ESQ.
HKM EMPLOYMENT ATTORNEYS LLP
Attorneys for Plaintiff
TERRENCE WHITTIER

14

/s/Sandra Ketner
PATRICK H. HICKS, ESQ.
SANDRA KETNER, ESQ.
LITTLER MENDELSON, P.C.
Attorneys for Defendant
CAESARS ENTERPRISE SERVICES, LLC
(incorrectly named as “CAESARS
ENTERTAINMENT CORPORATION”)

15
16
17

ORDER

18

IT IS SO ORDERED.

19
20

U.S. MAGISTRATE JUDGE

21

26th
Dated this ______ day of February, 2018.

22
23
24
25

The Early Neutral Evaluation session scheduled for March 13, 2018 is VACATED and
RESCHEDULED to April 6, 2018 at 10:00 AM. The ENE confidential statement is due by 4:00 PM,
March 30, 2018. All else as stated in the Order setting the ENE (ECF No. 9) remains unchanged.

26
27
28
LITTLE R MEND ELSO N, P .C .
ATTORNEYS AT LAW
200 S. Virginia St.
8th Floor
Reno, NV 89501
775.348.4888

Firmwide:153052335.1 079206.1009

2.