Gannon v. ASC Operations, LLC

Filing 29

ORDER Granting 27 Motion to Continue Re: 22 Motion to Compel, 21 Motion. IT IS HEREBY ORDERED that the hearing scheduled for 5/7/19, is VACATED, and RESCHEDULED to 1:00 PM, 5/9/19, in Courtroom 3D.Signed by Magistrate Judge Cam Ferenbach on 5/1/2019. (Copies have been distributed pursuant to the NEF - ADR)

1 Janice M. Michaels
Nevada Bar No. 6062
2 [e-mail]
Christina M. Mamer
3 Nevada Bar No. 13181
[e-mail]
4 Wood, Smith, Henning & Berman LLP
2881 Business Park Court, Suite 200
5 Las Vegas, NV 89128-9020
Telephone: [phone]
6 Facsimile: 702 251 5405
7 Attorneys for ASC OPERATIONS, LLC
8
UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA, SOUTHERN DIVISION

11
Attorneys at Law
2881 BUSINESS PARK COURT, SUITE 200
LAS VEGAS, NEVADA 89128-9020
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

9

12 CHRISTINA M. GANNON, an individual,
13
14

Plaintiff,

Case No. 2:18-CV-00533-KJD-VCF
MOTION TO CONTINUE MAY 7, 2019
HEARING DATE

v.

15 ASC OPERATIONS, LLC, a Domestic
Limited-Liability Company; DOES I through
16 X, inclusive; ROE CORPORATIONS I
through X, inclusive,
17
Defendants.
18
19
20

MOTION TO CONTINUE MAY 7, 2019 HEARING DATE
Defendant, ASC OPERATIONS, LLC ("Defendant"), by and through its attorney of record,

21 the law firm of WOOD SMITH HENNING & BERMAN, LLP hereby moves to extend the hearing
22 set for May 7, 2019 regarding Plaintiff's Motion to Withdraw Admission Responses and Plaintiff's
23 Motion to Compel Defendant to Substantively Written Discovery Requests and for Sanctions [ECF
24 26] . The undersigned Defendant Counsel is unavailable on May 7, 2019 due a mediation at 9:00 a.m.
25 on another matter with the Honorable Jackie Glass (Retired), which has been set since the beginning
26 of the year. This request is made in good faith and not being for purposes of delay.
27

Defendant's Counsel has communicated with Plaintiff's Counsel, Trevor Hatfield, who has

28 confirmed that he has no opposition to moving the hearing date to another mutually available date.
LEGAL:10365-0046/11489730.1

Case No. 2:18-CV-00533-KJD-VCF
MOTION TO EXTEND MAY 7, 2019 HEARING DATE

1

Based on the foregoing, Defendant respectfully request that the Court extend the May 7, 2019

2 hearing date to another mutually-available date.
3 DATED: April 30, 2019

WOOD, SMITH, HENNING & BERMAN LLP

4
5

By:

6
7

/s/ Christina M. Mamer
JANICE M. MICHAELS
CHRISTINA M. MAMER
Attorneys for ASC OPERATIONS, LLC

8
9

11
Attorneys at Law
2881 BUSINESS PARK COURT, SUITE 200
LAS VEGAS, NEVADA 89128-9020
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

10

12

IT IS HEREBY ORDERED that the hearing scheduled for May 7, 2019, is VACATED, and
RESCHEDULED to 1:00 PM, May 9, 2019, in Courtroom 3D.

13
14
15
16
17
18

5-1-2019

19
20
21
22
23
24
25
26
27
28
LEGAL:10365-0046/11489730.1

Case No. 2:18-CV-00533-KJD-VCF
-2MOTION TO EXTEND MAY 7, 2019 HEARING DATE

1
2

CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of April, 2019, a true and correct copy MOTION TO

3 CONTINUE MAY 7, 2019 HEARING DATE was served via the United States District Court
4 CM/ECF system on all parties or persons requiring notice.
5
By /s/ Christina M. Mamer
Christina M. Mamer, an Employee of
WOOD, SMITH, HENNING & BERMAN LLP

6
7
8
9

11
Attorneys at Law
2881 BUSINESS PARK COURT, SUITE 200
LAS VEGAS, NEVADA 89128-9020
TELEPHONE [phone] ♦ FAX [phone]

WOOD, SMITH, HENNING & BERMAN LLP

10

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LEGAL:10365-0046/11489730.1

Case No. 2:18-CV-00533-KJD-VCF
-3MOTION TO EXTEND MAY 7, 2019 HEARING DATE