Meza-Perez v. Sbarro LLC, et al

Filing 193

ORDER granting 192 Stipulation to Extend Deadline to Reply to 180 Motion for Attorney Fees; Replies due by 1/20/2021. Signed by Judge Andrew P. Gordon on 1/8/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:19-cv-00373-APG-NJK Document 193 Filed 01/08/21 Page 1 of 2

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MARK E. FERRARIO
Nevada Bar No. 1625
JASON K. HICKS
Nevada Bar No. 13149
GREENBERG TRAURIG, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
Telephone: [phone]
Fax:
[phone]
Email: [e-mail]
[e-mail]

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Attorneys for Dana Dorado

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Greenberg Traurig, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
[phone]
[phone] (fax)

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SANDRA M. MEZA-PEREZ, an individual,

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Plaintiff,

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v.
SBARRO LLC dba SBARRO PIZZA, a
foreign limited liability company; SBARRO,
INC. dba SBARRO PIZZA, a foreign
corporation; ZACHARY CEBALLES, an
individual; EFRAIN HERNANDEZ, an
individual; JESUS ALATORRE, an
individual; DANA DORADO, an individual,

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Defendants.

Case No.: 2:19-cv-373-APG-NJK
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR DANA
DORADO TO SUBMIT HER REPLY IN
SUPPORT OF HER MOTION FOR
ATTORNEY’S FEES AND COSTS
PURSUANT TO THE COURT’S ORDER
GRANTING RULE 11 SANCTIONS
AGAINST PLAINTIFF’S COUNSEL [ECF
180]
(First Request)

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IT IS HEREBY STIPULATED AND REQUESTED by and between Plaintiff’s counsel

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Melanie Hill and Hardeep Sull on the one hand and Dana Dorado on the other, through their

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respective counsel and pursuant to Local Rules IA 6-1, LR IA 6-2, and LR 7-1, that the Court extend

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the deadline for Ms. Dorado to submit her Reply in support of her Motion for Attorney’s Fees and

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Costs Pursuant to the Court’s Order Granting Rule 11 Sanctions (the “Motion”), up to, and

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including, January 20, 2021. This stipulation is made and based upon the following:

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1.

On September 30, 2020, the Court entered an order granting Ms. Dorado’s Motion

for Sanctions under Rule 11. ECF No. 177.

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Error! Unknown document property name.

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Case 2:19-cv-00373-APG-NJK Document 193 Filed 01/08/21 Page 2 of 2

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2.

That order directed Ms. Hill, Ms. Sull, and Ms. Dorado to confer about the amount

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of fees and costs to be awarded pursuant to that order and, if they could not agree, to brief the matter

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for the Court.

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3.

The parties were unable to agree on the amount of costs and fees to be awarded

therefore Ms. Dorado submitted the Motion on November 30, 2020.

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4.

By stipulation, Ms. Hill and Ms. Sull submitted their opposition to the Motion on

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January 4, 2021.

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5.

Ms. Dorado’s reply is currently due on January 11, 2021.

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6.

Ms. Hill, Ms. Sull, and Ms. Dorado agree and request that Ms. Dorado have up to,

and including, January 20, 2021, to file her reply in support of the Motion. This request is made

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Greenberg Traurig, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
[phone]
[phone] (fax)

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in order to accommodate competing obligations held by Ms. Dorado’s counsel and agreed to by

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Ms. Hill’s and Ms. Sull’s counsel as a professional courtesy.

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7.

This is the first request for the relief sought herein, made in good faith and not for

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purposes of delay.

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Dated this 8th day of January 2021.

Dated this 8th day of January 2021.

/s/ Joseph Garin
JOSEPH P. GARIN, ESQ.
Nevada Bar No. 6653
LIPSON NEILSON P.C.
990 Covington Cross Dr., Suite 120
Las Vegas, NV 89144

/s/ Jason K. Hicks
MARK E. FERRARIO, ESQ.
Nevada Bar No. 1625
JASON K. HICKS, ESQ.
Nevada Bar No. 13149
GREENBERG TRAURIG, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, NV 89135

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Counsel for Melanie Hill and Hardeep Sull

Counsel for Dana Dorado

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IT IS SO ORDERED.

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UNITED STATES DISTRICT JUDGE

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8th
Dated this ___ day of January 2021.

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Error! Unknown document property name.

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