Ramirez v. Wynn Las Vegas, LLC

Filing 177

ORDER Granting 176 Stipulation for Extension of Time re 174 Motion for Remittitur and 175 Motion for Sanctions. Responses due by 12/17/2024. Replies due by 1/15/2025. Signed by Chief Judge Andrew P. Gordon on 11/25/2024. (Copies have been distributed pursuant to the NEF - RJDG)

1
2
3
4
5
6
7
8

Christian Gabroy
(#8805)
Kaine Messer
(#14240)
Gabroy | Messer
The District at Green Valley Ranch
170 South Green Valley Parkway
Suite 280
Henderson, Nevada 89012
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
Tiare Ramirez

9
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

10

GABROY | MESSER

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

11

TIARE RAMIREZ, an individual;

Case No. 2:19-cv-01174-APG-EJY

Plaintiff,

12

STIPULATION AND ORDER TO
EXTEND DEADLINE

vs.
13
14

WYNN LAS VEGAS, LLC; DOES I
through X; and ROE Corporations XI
through XX inclusive,

15
Defendant.

(1) TO FILE PLAINTIFF’S
RESPONSE TO DEFENDANT’S
MOTION FOR REMITTITUR ECF
NO. 174 AND MOTION FOR
SANCTIONS ECF NO. 175

16
AND
17
18

(2) TO FILE DEFENDANT’S
REPLY THERETO

19

(First Request)

20
21
22

STIPULATION AND ORDER TO EXTEND DEADLINE (1) TO FILE
RESPONSE TO DEFENDANT’S MOTION FOR REMITTITUR ECF NO. 174
AND MOTION FOR SANCTIONS ECF NO. 175 AND (2) TO FILE
DEFENDANT’S REPLY THERETO

23

The Parties, by and through their respective attorneys of record, hereby

24

stipulate that Plaintiff’s Response to Defendant’s Motion for Remittitur (ECF No.

25

174) and Motion for Sanctions (ECF No. 175) (together Defendant’s “Motion”)

26

shall be extended fourteen (14) days to December 17, 2024. Defendant’s Motion

27

was filed on November 17, 2024 and Plaintiff’s Opposition is currently due on

28

December 3, 2024. See LR 7-2(b). Additionally, the parties further agree that
Page 1 of 3

GABROY | MESSER

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

1

Defendant’s Reply thereto shall be due no later than January 15, 2025. This is the

2

parties’ first request for an extension of these deadlines.

3

Good cause supports this request. Lead counsel for Plaintiff had a recent

4

death in the family requiring his attention. Plaintiff’s counsel has additional staffing

5

issues necessitating the extension. The parties further believe good cause exists

6

for Defendant’s reply to be due by January 15, 2025, as the extended deadline for

7

the opposition would otherwise require Defendant’s reply to be due in the midst of

8

the holidays conflicting with planned travel and time away from the office.

9

Therefore, Plaintiff’s Response to Defendant’s Motions, ECF 174 and

10

175, shall be due no later than Tuesday, December 17, 2024 and Defendant’s

11

Reply thereto shall be due no later than Wednesday, January 15, 2025.

12

///

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 2 of 3

1
2
3

This stipulation is made in good faith and not for purposes of delay. No
party is prejudiced by this stipulation.
IT IS SO STIPULATED.

4

Dated: November 22, 2024

Dated: November 22, 2024

5

Respectfully submitted,

Respectfully submitted,

/s/ Christian Gabroy
Christian Gabroy
(#8805)
Kaine Messer
(#14240)
The District at Green Valley Ranch
170 South Green Valley Parkway
Suite 280
Henderson, Nevada 89012
Tel: [phone]
[e-mail]
[e-mail]

/s/ Wendy M. Krincek
Patrick H. Hicks, Esq.
(#4632)
Wendy M. Krincek
(#6147)
Kelsey E. Stegall
(#14279)
3960 Howard Hughes Parkway
Suite 300
Las Vegas, Nevada 89169
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]

6
7
8
9
10

GABROY | MESSER

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

11
12
13
14
15

Attorneys for Plaintiff
Tiara Ramirez

Attorneys for Defendant
Wynn Las Vegas, LLC

16
17
18

IT IS SO ORDERED.

19
20
21
22

_________________________________________
UNITED STATES DISTRICT JUDGE
Dated: November 25, 2024

23
24
25
26
27
28
Page 3 of 3