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)

Case 2:19-cv-02159-JCM-BNW Document 110 Filed 04/21/21 Page 1 of 3

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Burke Huber
Nevada State Bar No. 10902
RICHARD HARRIS LAW FIRM
801 South 4th Street
Las Vegas, Nevada 89101
Tel: [phone]
Email: [e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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BRENNA SCHRADER, an individual, on
behalf of herself and all others similarly
situated,
Plaintiff,

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vs.

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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.

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IT IS HEREBY STIPULATED by and between Plaintiff, Brenna Schrader, (“Plaintiff”),

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through her counsel Burke Huber, at the Richard Harris Law Firm, and Defendants, Wynn Las

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Vegas, LLC (“Defendant WLV”) and Wynn Resorts, Ltd. (“Defendant WRL”), through their

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counsel Jackson Lewis P.C., Defendant, Stephen Alan Wynn (“Mr. Wynn”), through his counsel

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Peterson Baker, PLLC, and Defendant, Maurice Wooden (“Mr. Wooden”), by and through his

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counsel Kennedy & Couvillier, (collectively “Defendants”), that Plaintiff shall have an extension

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up to and including May 24, 2020 to file a response to motions to dismiss.

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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:

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1.

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Nos. 98, 99].
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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].
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Due to the complexity of the motions filed and Mr. Huber’s need to continue home

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schooling for the time being, Plaintiff respectfully seeks an extension up to and including May 24,

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2021 to file responses.
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In anticipation of potential Coronavirus obstacles and to avoid the need of filing an

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additional stipulation, the parties also stipulate the Defendants’ Replies to Plaintiff’s responses to

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Defendants’ motions to dismiss will be due three weeks later, on June 14, 2021.
5.

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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.

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This is the first stipulation related to Defendants’ replies.

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7.

This request is made in good faith and not for the purpose of delay.

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Case 2:19-cv-02159-JCM-BNW Document 110 Filed 04/21/21 Page 3 of 3

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8.

Nothing in this Stipulation, nor the fact of entering to the same, shall be construed

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as waiving any claim and/or defense held by any party.

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Dated this 21st day of April, 2021.

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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.

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ORDER

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IT IS SO ORDERED:

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United States District Court/Magistrate Judge
UNITED STATES DISTRICT JUDGE

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April 26, 2021
Dated: _________________________

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4836-9391-3787, v. 1

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