Bryant v Madison Management Services, LLC, et al

Filing 13

ORDER granting 12 TIPULATION FOR EXTENSION OF TIME (Second Request) to File Response to: 9 Motion to Dismiss. Responses due by 7/2/2020. Replies due by 7/9/2020. Signed by Judge Jennifer A. Dorsey on 6/3/2020. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00594-JAD-EJY Document 13 Filed 06/03/20 Page 1 of 2

1 George Haines, Esq.
Nevada Bar No. 9411

2 HAINES & KRIEGER, LLC
3 8985 S. Eastern Ave., Suite 350
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Las Vegas, NV 89123
Phone: [phone]
FAX: [phone]
Email: [e-mail]
Attorney for Plaintiff
Lisa A. Bryant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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LISA A. BRYANT,

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Plaintiff,

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v.

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MADISON MANAGEMENT SERVICES,
13 LLC, AND PORRAS, PLLC,

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Defendant.

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Pursuant to Local Rule 7-1, Plaintiff Lisa A. Bryant (“Plaintiff”) and Defendants Madison

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) Civil Case No. 2:20-cv-00594-JAD-EJY
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STIPULATION AND ORDER TO
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CONTINUE MOTION TO DISMISS
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RESPONSE DEADLINES
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(FIRST REQUEST)
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Management Services, LLC and Porras, PLLC (“Lisa A. Bryant”, and together with Defendant, the

20 “Parties”), by and through their respective undersigned counsel of record, submit this Stipulation and
21 Proposed Order.
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

Plaintiff filed a Complaint (the “Complaint”) in this Court on March 27, 2020;

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

Defendants filed its Motion to Dismiss on May 20, 2020; and

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

Plaintiff’s opposition is currently due on June 3, 2020.

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The parties are requesting an extension of at least 30-days. This is the first stipulation for

28 extension of time to file responses to the Motion to Dismiss filed on May 20, 2020. The Plaintiff is

Case 2:20-cv-00594-JAD-EJY Document 13 Filed 06/03/20 Page 2 of 2

1 requesting the extension due to some recent staff changes at Haines & Krieger, LLC and that certain
2 staff members were temporarily limited by their personal situations that were directly impacted by
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COVID-19.

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IT IS HEREBY STIPULATED AND AGREED Plaintiff’s deadline to file and serve any point
and authorities in response to the motion shall be extended 30-days and shall be due on or before July

7 2, 2020.
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IT IS FURTHER STIPULATED AND AGREED Defendant’s deadline to file and serve any

9 reply in support of its motion shall be extended by at least 30-days and shall be due on July 9, 2020.
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Dated: May 29, 2020

Dated: May 29, 2020

HAINES & KRIEGER, LLC

WALDMAN & PORRAS, PLLC

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By: /s/ Nicholas M. Porras
Nicholas M. Porras, Esq. NV Bar 12849
201 West Liberty St. Ste.207
Reno, Nevada 89501

By: /s/George Haines___________
George Haines, Esq. NV Bar 9411
8985 S. Eastern Ave, Suite 350

Attorneys for Defendants

Las Vegas, NV 89123

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ORDER

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IT IS SO ORDERED:

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
Dated: June 3, 2020.

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DATED: ____________________________

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