Schrader v. Wynn et al

Filing 113

ORDER granting 110 Stipulation to Extend time Re: 98 Motion to Dismiss, 103 Motion, 99 Motion to Dismiss; Responses due by 5/24/2021. Replies due by 6/14/2021. Signed by Judge James C. Mahan on 4/26/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Case 2:19-cv-02159-JCM-BNW Document 110 Filed 04/21/21 Page 1 of 3 1 2 3 4 Burke Huber Nevada State Bar No. 10902 RICHARD HARRIS LAW FIRM 801 South 4th Street Las Vegas, Nevada 89101 Tel: (702) 444-4444 Email: burke@richarcharrislaw.com Attorneys for Plaintiff 5 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 9 BRENNA SCHRADER, an individual, on behalf of herself and all others similarly situated, Plaintiff, 10 vs. 11 12 13 14 15 Case No. 2:19-cv-02159-JCM-BNW STEPHEN ALAN WYNN; an individual; MAURICE WOODEN, an individual, WYNN LAS VEGAS, LLC dba WYNN LAS VEGAS a Nevada Limited Liability, WYNN RESORTS, LTD, a Nevada Limited Liability Company; and DOES 1-20, inclusive; ROE CORPORATIONS 1-20, inclusive, STIPULATION TO EXTEND DEADLINE FOR PLAINTIFF TO FILE A RESPONSE TO DEFENDANTS’ MOTIONS TO DISMISS (FIRST REQUEST – Response to Motions to Dismiss) Defendants. 16 17 18 19 IT IS HEREBY STIPULATED by and between Plaintiff, Brenna Schrader, (“Plaintiff”), 20 through her counsel Burke Huber, at the Richard Harris Law Firm, and Defendants, Wynn Las 21 Vegas, LLC (“Defendant WLV”) and Wynn Resorts, Ltd. (“Defendant WRL”), through their 22 counsel Jackson Lewis P.C., Defendant, Stephen Alan Wynn (“Mr. Wynn”), through his counsel 23 Peterson Baker, PLLC, and Defendant, Maurice Wooden (“Mr. Wooden”), by and through his 24 counsel Kennedy & Couvillier, (collectively “Defendants”), that Plaintiff shall have an extension 25 up to and including May 24, 2020 to file a response to motions to dismiss. 26 /// 27 /// 28 /// Case 2:19-cv-02159-JCM-BNW Document 110 Filed 04/21/21 Page 2 of 3 This Stipulation is submitted and based upon the following: 1 1. 2 3 Nos. 98, 99]. 2. 4 5 On March 31, 2021, Mr. Wooden and Mr. Wynn filed Motions to Dismiss [ECF On April 7, 2021, Defendants WLV and WRL filed a Partial Motion to Dismiss [ECF No. 90]. 3. 6 Due to the complexity of the motions filed and Mr. Huber’s need to continue home 7 schooling for the time being, Plaintiff respectfully seeks an extension up to and including May 24, 8 2021 to file responses. 4. 9 In anticipation of potential Coronavirus obstacles and to avoid the need of filing an 10 additional stipulation, the parties also stipulate the Defendants’ Replies to Plaintiff’s responses to 11 Defendants’ motions to dismiss will be due three weeks later, on June 14, 2021. 5. 12 13 This is the first request for an extension of time for Plaintiff to file a response to Defendants’ motions to dismiss, and for an extended period for Defendants’ reply briefs. 14 6. This is the first stipulation related to Defendants’ replies. 15 7. This request is made in good faith and not for the purpose of delay. 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 2 Case 2:19-cv-02159-JCM-BNW Document 110 Filed 04/21/21 Page 3 of 3 1 8. Nothing in this Stipulation, nor the fact of entering to the same, shall be construed 2 as waiving any claim and/or defense held by any party. 3 Dated this 21st day of April, 2021. 4 5 6 7 8 9 RICHARD HARRIS LAW FIRM JACKSON LEWIS P.C. /s/ Burke Huber Richard Harris, Bar No. 505 Benjamin Cloward, Bar No. 11087 Burke Huber, Bar No. 10902 801 S. Fourth Street Las Vegas, Nevada 89101 Attorney for Plaintiff Brenna Schrader /s/ Joshua A. Sliker Deverie J. Christensen, Bar No. 6596 Joshua A. Sliker, Bar No. 12493 Daniel Aquino, Bar No. 12682 300 S. Fourth Street, Ste. 900 Las Vegas, Nevada 89101 KENNEDY & COUVILLIER PETERSON BAKER, PLLC /s/ Maximiliano Couvillier Maximiliano D. Couvillier, Bar No. 7661 3271 E. Warm Springs Road Las Vegas, Nevada 89120 Attorney for Defendant Maurice Wooden /s/ Tamara Beatty Peterson ______ Tamara Beatty Peterson, Bar No. 5218 701 S. 7th Street Las Vegas, Nevada 89101 Attorney for Defendant Stephen Alan Wynn Attorneys for Defendants Wynn Las Vegas, LLC and Wynn Resorts, Ltd. 10 11 12 13 14 15 16 17 18 19 ORDER 20 IT IS SO ORDERED: 21 22 23 United States District Court/Magistrate Judge UNITED STATES DISTRICT JUDGE 24 25 April 26, 2021 Dated: _________________________ 26 27 28 4836-9391-3787, v. 1 3

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