Hale v. NV Property 1, LLC, et al

Filing 55

ORDER Granting 54 Stipulation for Extension of Time re 53 Order (Eighth Request). Motions due by 3/26/2021. Signed by Magistrate Judge Cam Ferenbach on 2/17/2021. (Copies have been distributed pursuant to the NEF - MR)

Case 2:19-cv-00780-JCM-VCF Document 55 Filed 02/17/21 Page 1 of 3

1
2
3
4
5
6

Lisa A. McClane, NV Bar No. 10139
Daniel I. Aquino, NV Bar No. 12682
JACKSON LEWIS P.C.
The Bank of America Plaza
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant
Nevada Property 1, LLC dba The Cosmopolitan of Las Vegas

7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

TONYA HALE,

11

Plaintiff,

12

vs.

13
14
15
16

Case No. 19-CV-00780-JCM-VCF
STIPULATION AND ORDER TO EXTEND
DISPOSITIVE MOTION DEADLINE

THE COSMOPOLITAN OF LAS VEGAS;
NV PROPERTY 1, LLC dba THE
COSMOPOLITAN OF LAS VEGAS, a
Nevada Limited Liability Company;
RICHARD SHERMAN, an individual,

Eighth Request

Defendants.

17
18

IT IS HEREBY STIPULATED by and between Tonya Hale (“Plaintiff”), and Nevada

19

Property 1, LLC, doing business as The Cosmopolitan of Las Vegas (“TCOLV”) and (collectively

20

referred to as the “Parties”), by and through their respective counsel of record, hereby stipulate to

21

extend the deadline to file dispositive motions in this case, and agree as follows:

22

1.

On November 15, 2019, this Court entered an Order granting the initial Stipulated

23

Discovery Plan and Scheduling Order [ECF No. 31] and agreed to extend the initial deadlines on

24

February 5, 2020 [ECF No. 35].

25
26
27
28
JACKSON LEWIS P.C.
LAS VEGAS

2.

On April 2, 2020, this Court entered an Order granting the second request to extend

the Discovery Plan and Scheduling Order [ECF No. 38], on June 24, 2020 this.
3.

On June 24, 2020 this Court entered an Order granting the parties third request to

extend the Discovery Plan and Scheduling Order [ECF No. 41] and on September 15, 2020 this

Case 2:19-cv-00780-JCM-VCF Document 55 Filed 02/17/21 Page 2 of 3

1

Court entered an Order granting the parties fourth request to extend the Discovery Plan and

2

Scheduling Order [ECF No. 47].
4.

3

On October 20, 2020, this Court entered an Order granting the parties fifth request

4

to extend the Discovery Plan and Scheduling Order. [ECF No. 48]. Pursuant to the Court’s order

5

the deadline to file dispositive deadline is December 23, 2020.
5.

6

On December 21, 2020, this Court entered an Order granting the parties sixth request

7

to extend the dispositive motion deadline. [ECF No. 51]. Pursuant to the Court’s order the deadline

8

to file dispositive deadline is January 25, 2021.
6.

9

On January 25, 2021, this Court entered an Order granting the parties seventh

10

request to extend the dispositive motion deadline. [ECF No. 53]. Pursuant to the Court’s order the

11

deadline to file dispositive deadline is February 24, 2021
6.

12

Defendant’s counsel’s office was closed for several weeks in December due to staff

13

member testing positive for Covid. Thereafter, Defendants’ counsel began experiencing her own

14

medical issues which significantly impacted her vision, which has only recently been fully restored.

15

Accordingly, the parties require an extension to file dispositive motion in this matter. For the above

16

stated reasons, the parties request that the dispositive motion deadline be extended thirty (30) days

17

from to February 24, 2021 to March 26, 2021.
7.

18
19

Accordingly, the parties stipulate and agree to extend the dispositive motion

deadline for thirty (30) days, up to and including March 26, 2021.
8.

20

As set forth in ECF No. 53, upon the filing of a dispositive motion, the date for filing

21

the joint pretrial order shall be suspended until 30 days after decision on the dispositive motions or

22

until further order of the court.

23

///

24

///

25

///

26

///

27

///

28

///

JACKSON LEWIS P.C.
LAS VEGAS

-2-

Case 2:19-cv-00780-JCM-VCF Document 55 Filed 02/17/21 Page 3 of 3

1

9.

A trial date has not yet been set in this matter, and no other deadlines are affected

2

by this stipulation.

3

This stipulation and order is sought in good faith and not for the purpose of delay.

4

Dated this 17th day of February, 2021.

5

LAW OFFICES OF MICHAEL P. BALABAN

JACKSON LEWIS P.C.

8

/s/
Michael P. Balaban
Michael P. Balaban, NV Bar No. 9370
10726 Del Rudini St
Las Vegas, NV 89141-4216

9

Attorney for Plaintiff Tonya Hale

/s/ Lisa A. McClane
Lisa A. McClane, NV Bar No. 10139
Daniel I. Aquino, NV Bar No. 12682
Bank of America Plaza
300 S. Fourth St., Ste. 900
Las Vegas, Nevada 89101

6
7

10

Attorneys for Defendant Nevada Property 1
LLC dba The Cosmopolitan of Las Vegas

11
12

ORDER

13
14

IT IS SO ORDERED

February 17

, 2021.

15
16

U.S. Magistrate Judge

17
18

4815-2681-5965, v. 1

19
20
21
22
23
24
25
26
27
28
JACKSON LEWIS P.C.
LAS VEGAS

-3-