Garibaldi v. Boyd Gaming Corporation

Filing 20

ORDER granting 18 Stipulation; Early Neutral Evaluation set for 2/28/2022 at 09:00 AM. IT IS FURTHER ORDERED that the pre-ENE Telephonic Conference set for 1/11/2022 is hereby VACATED and will not be rescheduled. Signed by Magistrate Judge Brenda Weksler on 1/7/2022. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:21-cv-01444-GMN-DJA Document 18 Filed 01/06/22 Page 1 of 3
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01/07/22
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1 H1 LAW GROUP
Jill Garcia, NV Bar No. 7805
2 [e-mail]
Amy L. Howard, NV Bar No. 13946
3 [e-mail]
701 N. Green Valley Parkway, Suite 200
4 Henderson, NV 89074
Phone [phone]
702-703-1063
5 Fax
6 Attorneys for Plaintiff

H1 LAW GROUP

UNITED STATES DISTRICT COURT

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701 N. Green Valley Parkway, Suite 200
Henderson, Nevada 89074
Tel: [phone]

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DISTRICT OF NEVADA

9 FEDERICO GARIBALDI, an individual,
Plaintiff,

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Case No. 2:21-cv-01444-GMN-DJA

JOINT REQUEST STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
DATE OF EARLY NEUTRAL
EVALUATION SESSION

vs.

12 BOYD GAMING CORPORATION, a Nevada
corporation; DOES I through X, inclusive; and
13 ROE BUSINESS ENTITIES, I through X,
inclusive,
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Defendant.
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[First Request]

Plaintiff Federico Garibaldi (“Plaintiff”) and Defendant Boyd Gaming Corporation

17 (“Defendant”) (“Parties”), by and through their respective undersigned counsel, submit the
18 following Joint Request and [Proposed] Order to Continue the January 12, 2022 Early Neutral
19 Evaluation (“ENE”) [ECF No. 9] request as follows:
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1.

On August 31, 2021, the Court scheduled the ENE for December 10, 2021 and

21 further set the deadline to submit Confidential ENE Statements for December 3, 2021. [ECF No.
22 9].
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2.

Due to a conflict in the Court’s calendar, on November 17, 2021, the Court filed

24 an Order Scheduling Early Neutral Evaluation Session (“Order”) for January 12, 2022 and
25 further set the deadline to submit Confidential ENE Statements for January 5, 2022. [ECF No.
26 17].
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3.

On January 5, 2021, the parties each submitted their Confidential ENE Statements

28 to the Court.

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Case 2:21-cv-01444-GMN-DJA Document 18 Filed 01/06/22 Page 2 of 3
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01/07/22
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4.

Plaintiff just informed his counsel that he has accepted a job after a long and

2 arduous three-year search for replacement employment. Unfortunately, Plaintiff’s new job starts
3 on Tuesday, January 11, 2022, and he has been unable to secure time off for the ENE currently
4 scheduled for January 12, 2022.
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5.

Therefore, the Parties respectfully request the ENE Session be continued for thirty

6 (30) days such that Plaintiff can establish his new employment and request time off to attend the
7 ENE Session.

H1 LAW GROUP

701 N. Green Valley Parkway, Suite 200
Henderson, Nevada 89074
Tel: [phone]

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6.

The Parties and their client representatives are available on February 28, 2022.

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7.

The Parties hereby request that the Court continue the January 12, 2022 ENE for

10 February 28, 2022.
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8.

This Joint Request and Proposed Order is sought in good faith and not for the

12 purposes of delay.
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9.

This is the first request to continue the ENE.

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IT IS SO STIPULATED.

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Dated this 6th day of January 2022.

Dated this 6th day of January 2022.

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H1 LAW GROUP

KAMER ZUCKER ABBOTT

/s/Amy L. Howard
Jill Garcia, NV Bar No. 7805
[e-mail]
Amy L. Howard, NV Bar No. 13946
[e-mail]
701 N. Green Valley Parkway, Suite 200
Henderson, NV 89074
Phone [phone]
Fax
702-703-1063

/s/Jen J. Sarafina_________________
Jen J. Sarafina, NV Bar No. 9679
[e-mail]
Kaitlin H. Paxton, NV Bar No. 13625
[e-mail]
3000 W. Charleston Blvd., Ste. 3
Las Vegas, NV 89102
Phone [phone]
Fax
702-259-8646

Attorneys for Plaintiff

Attorneys for Defendant

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ORDER
IT IS ORDERED that ECF No. 18 is GRANTED. The Settlement Conference is
rescheduled to 2/28/2022 at 9:00 a.m. IT IS FURTHER ORDERED that the pre-ENE
Telephonic Conference set for 1/11/2022 is hereby VACATED and will not be
rescheduled.
IT IS SO ORDERED
DATED: 1:09 pm, January 07, 2022

BRENDA WEKSLER
UNITED STATES MAGISTRATE JUDGE

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