Allen v. Vocatus, LLC et al

Filing 47

ORDER Granting 46 Stipulation for Extension of Time (Second Request) for Plaintiff Erin Allen to File Response re 35 Defendants' Motion for Summary Judgment. Responses due by 8/17/2022. Signed by Judge Andrew P. Gordon on 8/2/2022. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:21-cv-00377-APG-DJA Document 47 Filed 08/02/22 Page 1 of 3

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JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
E-mail: [e-mail]
SARA SCHREIBER, ESQ.
Nevada Bar No. 15320
E-mail: [e-mail]
MICHAEL ARATA, ESQ.
Nevada Bar No. 11902
E-mail: [e-mail]
HKM EMPLOYMENT ATTORNEYS LLP
101 Convention Center Drive, Suite 600
Las Vegas, Nevada 89109
Tel: [phone]
Fax: [phone]

Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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ERIN ALLEN, an Individual,
CASE NO.: 2:21-cv-00377-APG-DJA

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Plaintiff,
vs.

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VOCATUS, LLC, a Nevada Limited
Liability Company; SHAMOUN’S, LLC, a
Nevada Limited Liability Company, DOES
1-50, inclusive and ROE CORPORATIONS
1-50, inclusive,

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STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF ERIN
ALLEN TO FILE RESPONSE TO
DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT

Defendant.

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Plaintiff Erin Allen (“Allen”), and Defendants Vocatus, LLC and Shamoun’s, LLC

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(together “Defendants”), by and through their respective attorneys of record, stipulate as

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follows:

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1.

On May 4, 2022, Defendants filed their Motion for Summary Judgment. [ECF

No. 35].
2.

On May 25, 2022, Plaintiff, through her prior counsel, filed a Motion to Extend

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Time to Respond to Motion for Summary Judgment [ECF No. 36], to which Defendants

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responded the same day. [ECF No. 37].

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STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF ERIN ALLEN TO FILE RESPONSE
TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

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Case 2:21-cv-00377-APG-DJA Document 47 Filed 08/02/22 Page 2 of 3

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3.

withdraw as counsel for Plaintiff. [ECF No. 38].

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On May 31, 2022, Plaintiff’s prior counsel, Trevor Hatfield, Esq., moved to

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On June 2, 2022, Defendants filed their response to the motion to withdraw.

[ECF No. 40].

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On June 3, 2022, this Court denied Mr. Hatfield’s motion to withdraw as

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Plaintiff’s counsel without prejudice and permitted Mr. Hatfield until June 17, 2022, to file a

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corrected motion to withdraw. [ECF No. 41].

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for Plaintiff. [ECF No. 42].

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On June 16, 2022, Mr. Hatfield filed a renewed motion to withdraw as counsel

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Defendants filed their notice of non-opposition to the motion to withdraw on

June 20, 2022. [ECF No. 43].
8.

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On June 28, 2022, this Court granted Plaintiff’s prior counsel’s motion to

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withdraw and ordered that Plaintiff: (1) shall have until July 13, 2022, to retain new counsel or

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inform the Court whether she will proceed pro se; and (2) shall have until August 3, 2022, to

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respond to Defendants’ Motion for Summary Judgment. [ECF No. 44].
9.

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Attorneys LLP, appeared on Plaintiff’s behalf. [ECF No. 45].
10.

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On July 28, 2022, Plaintiff’s new counsel, HKM Employment Attorneys LLP,

received Plaintiff’s file from her prior counsel.
11.

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On July 18, 2022, Plaintiff’s new counsel of record, HKM Employment

The parties hereby stipulate and agree Plaintiff shall have fourteen (14)

additional days to file her response to Defendants’ Motion for Summary Judgment. The new
deadline for Plaintiff to file her response shall be August 17, 2022.
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STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF ERIN ALLEN TO FILE RESPONSE
TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

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Case 2:21-cv-00377-APG-DJA Document 47 Filed 08/02/22 Page 3 of 3

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12.

This is the second request for an extension of this deadline and is not made for

purposes of undue delay.
Dated: August 1, 2022.
HKM EMPLOYMENT ATTORNEYS, LLP OGLETREE, DEAKINS, NASH, SMOAK
&STEWART, P.C.
/s/ Jenny L. Foley
JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
E-mail: [e-mail]
SARA SCHREIBER, ESQ.
Nevada Bar No. 15320
E-mail: [e-mail]
MICHAEL ARATA, ESQ.
Nevada Bar No. 11902
E-mail: [e-mail]
101 Convention Center Drive, Suite 600
Las Vegas, Nevada 89109
Tel: [phone]
Fax: [phone]

/s/ Suzanne L. Martin
SUZANNE L. MARTIN, ESQ.
Nevada Bar No. 8833
E-mail: [e-mail]
MICHELLE C. KRAKORA, ESQ.
Nevada Bar No. 8832
E-mail:
[e-mail]
10801 W. Charleston Blvd., Suite 500
Las Vegas, Nevada 89135
Tel: [phone]
Fax: [phone]

Attorneys for Defendants Vocatus, LLC and
Shamoun’s, LLC

Attorneys for Plaintiff

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ORDER
IT IS SO ORDERED:
_________________________________________
UNITED STATES DISTRICT COURT JUDGE
CASE NO.: 2:21-cv-00377-APG-DJA
August 2, 2022
DATED: _________________________________

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STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF ERIN ALLEN TO FILE RESPONSE
TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

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