Lewis v. Sunrise Hospital and Medical Center, LLC

Filing 35

ORDER Granting 34 Stipulation for Extension of Time (First Request). Responses re 33 Motion for Summary Judgment due by 1/31/2023. Replies due by 2/28/2023. Signed by Judge Cristina D. Silva on 1/17/2023. (Copies have been distributed pursuant to the NEF - TRW)

Case 2:21-cv-00464-CDS-VCF Document 35 Filed 01/17/23 Page 1 of 3

Case 2:21-cv-00464-CDS-VCF Document 35 Filed 01/17/23 Page 2 of 3

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2. Plaintiff’s counsel has not had time to meet with Ms. Lewis to get her input in preparing

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the summary judgment response and will not be able to spend sufficient time on this until

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after January 17, 2023 due to the other deadlines set forth below and Ms. Lewis’s being

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located in North Carolina (necessitating working around time zone differences).
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3. Plaintiff’s counsel is experiencing a very heavy workload including another summary

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judgment opposition in another case (McIntosh vs. City of North Las Vegas) now due on

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January 23, 2023; another summary judgment opposition in another case (Matthys vs.

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Barrick Turquoise Ridge, Inc.) now due on January 30, 2023; and an opening brief due in

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a Ninth Circuit case (Raffele v. VCA, Inc.) also due on January 17, 2023. The other

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summary judgment deadlines herein have also been recently extended from earlier

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deadlines, but it is the appellate brief that is mostly driving the need for an extension here
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because it is due the same date as the summary judgment response due in this case,

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January 17, 2023.

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4. Additionally, Plaintiff’s counsel has had multiple administrative workers’ compensation

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hearings and appeals on January 9, 10, 12, and has others coming up on January 17, 24,

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and 27, 2023.

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5. The parties further stipulate that Defendant shall have a similar extension of the deadline
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to file its Reply to and including February 28, 2023.

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Case 2:21-cv-00464-CDS-VCF Document 35 Filed 01/17/23 Page 3 of 3

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Accordingly, additional time is needed and an extension to January 31, 2023 should be
sufficient. Defendant will also have an extension of the deadline to file its Reply until February
28, 2023.
IT IS SO STIPULATED.

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KEMP & KEMP, ATTORNEYS AT LAW

OGLETREE, DEAKINS, NASH, SMOAK & STEWART,
P.C.

/s/ James P. Kemp
James P. Kemp, Esq.
Nevada Bar No. 006375
7435 W. Azure Drive, Ste. 110
Las Vegas, NV 89130
Attorney for Plaintiff

/s/ Anthony L. Martin
Anthony L. Martin
Nevada Bar No. 8177
Noel M. Hernandez
Nevada Bar No. 13893
10801 W. Charleston Blvd.
Suite 500
Las Vegas, NV 89135
Attorneys for Defendant

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ORDER
IT IS SO ORDERED.

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_________________________________
UNITED STATES DISTRICT JUDGE

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January 17, 2023
DATE

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