Nosik v. All Bright Family Dentistry, LLC

Filing 59

ORDER Granting 58 Stipulation for Extension of Time re 55 Order (First Request). Joint Status Report and Discovery Plan/Scheduling Order due by 9/25/2020. Signed by Magistrate Judge Cam Ferenbach on 9/21/2020. (Copies have been distributed pursuant to the NEF - MR)

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Nannina L. Angioni (SBN 11041)
KAEDIAN LLP
3960 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant,
ALL BRIGHT FAMILY DENTISTRY, LLC
Michael P. Balaban (SBN 9370)
LAW OFFICES OF MICHAEL P. BALABAN
10726 Del Rudini Street
Las Vegas, NV 89141
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Plaintiff,
YVONNE NOSIK
UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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Case No.: 2:18-cv-00972-RFB-VCF

YVONNE NOSIK
Plaintiff,
v.
ALL BRIGHT FAMILY DENTISTRY,
LLC dba ALL BRIGHT DENTAL, a
Nevada Limited Liability Company

JOINT STIPULATION TO
REQUEST CONTINUANCE OF
DEADLINE TO SUBMIT JOINT
STATUS REPORT DUE TO
PLAINTIFF’S INTENDED
CHANGE OF COUNSEL AND
PROPOSED ORDER THEREON

Defendant.
Action Filed: 5/27/2018

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JOINT STIPULATION TO REQUEST CONTINUANCE OF DEADLINE & [PROPOSED] ORDER

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TO THE HONORABLE COURT:

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Plaintiff Yvonne A. Nosik (“Plaintiff”) and Defendant All Bright Family

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Dentistry, LLC d/b/a All Bright Dental (“Defendant”) (hereafter Plaintiff and

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Defendant are jointly referred to as the “Parties”), hereby jointly stipulate to respectfully

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request a brief continuance of the September 12, 2020 deadline to file a Joint Status

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Report and Proposed Discovery and Scheduling Order. The Parties submit this request

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because Plaintiff is currently in the process of engaging new counsel to represent her in

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this case.
STIPULATION

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1.

WHEREAS, on August 12, 2020, the Court denied Plaintiff’s Motion to

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Enforce Settlement and issued an order requiring the parties submit a Joint Status

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Report and Discovery Plan/Scheduling Order by September 12, 2020.

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2.

WHEREAS, On September 8, 2020, Plaintiff’s counsel Michael Balaban

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filed a Motion to Withdraw as Plaintiff’s Attorney in this case. As of the time of

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filing this Joint Stipulation and Request, the Court has not ruled on Mr. Balaban’s

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Motion.

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3.

WHEREAS, On September 11, 2020, Michelle Nisce of Prime Law

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Group notified Defendant’s counsel that Plaintiff intended to engage her to represent

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Plaintiff in this case. Ms. Nisce and Mr. Balaban informed Defendant’s counsel that

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they intend to file a Stipulation to Substitute Ms. Nisce in as Plaintiff’s counsel in this

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case. As of the time of filing this Joint Stipulation and Request, Plaintiff has not yet

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filed the Stipulation to Substitute counsel.

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4.

WHEREAS, Plaintiff’s intended new counsel Ms. Nisce indicated that

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she requires additional time to become Plaintiff’s counsel of record and get up to

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speed on the case before she can engage in meaningful discussions about a proposed

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Discovery and Scheduling Order.

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JOINT STIPULATION TO REQUEST CONTINUANCE OF DEADLINE & [PROPOSED] ORDER

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5.

WHEREAS, Plaintiff’s soon to depart counsel, Mr. Balaban, is unable to

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commit to deadlines in a Discovery and Scheduling Order given that he will not be

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involved in this case after Ms. Nisce steps in.

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6.

THUS, for the reasons listed above, the Parties jointly respectfully

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request the Court continue the September 12, 2020 deadline to file a Joint Status

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Report and Proposed Discovery and Scheduling Order to September 25, 2020.

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LAW OFFICES OF
MICHAEL P. BALABAN

KAEDIAN LLP

/s/ Michael P. Balaban
Michael P. Balaban, Esq.
10726 Del Rudini St.
Las Vegas, NV 89141
Attorney for Plaintiff,
Yvonne Nosik
Dated: September 12, 2020

/s/ Nannina L. Angioni
Nannina L. Angioni, Esq.
3690 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89169
Attorney for Defendant,
All Bright Family Dentistry
Dated: September 12, 2020

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ORDER
GOOD CAUSE HAVING BEEN SHOWN, the Court continues the September
12, 2020 deadline to file a Joint Status Report and Proposed Discovery and
Scheduling Order to September 25, 2020.
IT IS SO ORDERED.

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Dated: 9-21-2020

______________________________________
The Honorable Cam Ferenbach
United States Magistrate Judge

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JOINT STIPULATION TO REQUEST CONTINUANCE OF DEADLINE & [PROPOSED] ORDER