Cabrera et al v. Service Employees International Union et al

Filing 303

ORDER Granting 302 Stipulation for Extension of Time to file Reply Brief in Support of 269 Motion to Bifurcate Discovery or Trial. Replies due by 10/27/2023. Signed by Judge Richard F. Boulware, II on 10/20/2023. (Copies have been distributed pursuant to the NEF - AMMi)

1

CHRISTENSEN JAMES & MARTIN

2

EVAN L. JAMES, ESQ. (7760)
DARYL E. MARTIN, ESQ. (6735)
7440 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail], [e-mail]
Attorneys for Defendants Nevada Service Employees
Union, Luisa Blue, and Martin Manteca

3
4
5
6

CHRISTENSEN JAMES & MARTIN, CHTD.

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

7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

JAVIER CABRERA, et al.
Case No.: 2:18-cv-00304-RFB-DJA

11

Plaintiffs,

12
13

vs.

14
15

SERVICE EMPLOYEES
INTERNATIONAL UNION, et al.,

16

Defendants.

STIPULATION TO EXTEND
DEADLINE TO FILE REPLY IN
SUPPORT OF MOTION TO
BIFURCATE TRIAL
(FIRST REQUEST)

17
18

Pursuant to LR IA 6-1, Plaintiff Debbie Miller and Defendants Service

19

Employees International Union (“SEIU”) and Clark County Public Employees

20

Association dba Nevada Service Employees Union (“Local 1107”) (collectively the

21

“Parties”), acting through their respective counsel of record, respectfully submit this

22

Stipulation to Extend Deadline to file a Reply Brief in Support of the Defendants’

23

Motion to Bifurcate Trial (ECF 269). This is the first request for an extension of time

24

to file a Reply in support of said motion.

25

On Friday, October 13, 2023, Plaintiff Debbie Miller filed an Opposition to

26

Defendants’ Motion to Bifurcate Trial. Daryl Martin has been tasked with preparing

27

Defendants’ Reply brief, but he has been unable to devote time to the matter, having

1

traveled outside the State of Nevada during two of the four intervening weekdays

2

since Miller filed her Opposition. Miller’s counsel has therefore agreed to extend the

3

deadline to file a Reply brief by one week, from October 20 to October 27, 2023.

4

This extension is being requested in good faith and will not delay further proceedings

5

in this Case.

6

CHRISTENSEN JAMES & MARTIN

ROTHNER, SEGALL & GREENSTONE

7
8
9
10
11
12
13
14
15
16
17
18
19

By: /s/ Daryl E. Martin
Daryl E. Martin, Esq.
Nevada Bar No. 6735
7440 W. Sahara Avenue
Las Vegas, NV 89117
Tel.: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendants Local
1107, Luisa Blue, and
Martin Manteca

By: /s/ Eli Naduris-Weissman
Eli Naduris-Weissman, Esq.
Pro Hac Vice
510 S. Marengo Ave.
Pasadena, California 91101-3115
Tel.: [phone]
[e-mail]
Attorneys for Defendants SEIU and
Mary Kay Henry

By: /s/ Michael J. Mcavoyamaya
Michael J. Mcavoyamaya, Esq.
Nevada Bar No. 14082
4539 Paseo Del Ray
Las Vegas, NV 89121
Tel.: [phone]
[e-mail]
Attorney for Plaintiff Debbie Miller

20
21

ORDER

22

Good cause appearing, the Court grants the foregoing Stipulation to Extend

23

Deadline to file Reply Brief in Support of Motion to Bifurcate Trial. Defendants’

24

Reply brief shall be filed on or before October 27, 2023.

25
26

United States District Court Judge

27

Dated: October 20, 2023
-2-