White v. TK Elevator Corporation

Filing 38

ORDER granting 37 Stipulation to Extend Time to File Opposition and Reply to 36 Motion to Compel. Opposition due by 11/22/2023. Replies due by 12/4/2023. Signed by Magistrate Judge Cam Ferenbach on 11/13/2023. (Copies have been distributed pursuant to the NEF - CT)

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REBECCA L. MASTRANGELO, ESQ.
Nevada Bar No. 5417
ROGERS, MASTRANGELO, CARVALHO & MITCHELL
700 S. Third Street
Las Vegas, Nevada 89101
Phone [phone]
Fax [phone]
[e-mail]
Attorneys for Defendant
TK ELEVATOR CORPORATION f/k/a
THYSSENKRUPP ELEVATOR CORPORATION

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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NATHAN WHITE,

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CASE NO. 2:21-cv-01696-ART-VCF
Plaintiff,
STIPULATION AND ORDER TO
EXTEND TIME TO FILE
OPPOSITION AND REPLY

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vs.

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TK ELEVATOR CORPORATION f/k/a
THYSSENKRUPP
ELEVATOR
CORPORATION; DOES I through X, inclusive;
and ROE BUSINESS ENTITIES I through X,
inclusive,

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Defendants.

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IT IS HEREBY STIPULATED between Plaintiff, Nathan White, and Defendant, TK Elevator
Corporation f/k/a Thyssenkrupp Elevator Corporation, by and through their respective counsel of
record, that the time to file an Opposition to Plaintiff’s Motion to Compel [36] filed on November
3, 2023 be extended, through and including November 22, 2023, and Plaintiff will have to and
including December 4, 2023 to reply to Defendant’s opposition.
Dated this __ day of November, 2023.

Dated this __ day of November, 2023.

SHOOK & STONE, CHTD.

ROGERS, MASTRANGELO, CARVALHO &
MITCHELL

/s/ John B. Shook
___________________________________
John B. Shook Esq.
Nevada Bar No. 5499
Lynn R. Shoen, Esq.
Nevada Bar No. 1197
710 S. Fourth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff

/s/ Rebecca L. Mastrangelo

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Rebecca L. Mastrangelo, Esq.
Nevada Bar No. 5417
700 South Third Street
Las Vegas, Nevada 89101
Attorneys for Defendant

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ORDER
November
13th day of ________________,
IT IS SO ORDERED this ____
2023.

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______________________________
U.S. MAGISTRATE JUDGE

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SUBMITTED BY:
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ROGERS, MASTRANGELO, CARVALHO
& MITCHELL
/s/ Rebecca L. Mastrangelo
_______________________________
REBECCA L. MASTRANGELO, ESQ.
Nevada Bar No. 5417
700 S. Third Street
Las Vegas, Nevada 89101
Attorney for Defendant

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Carolyn Mangundayao
Subject:

RE: TK adv. White

From: Lynn Shoen <[e-mail]>
Sent: Thursday, November 9, 2023 3:43 PM
To: Rebecca Mecham <[e-mail]>; Rebecca Mastrangelo <[e-mail]>; Kiana A.
O'Day <KO'[e-mail]>; John Shook <[e-mail]>
Cc: Kathy Vigil <[e-mail]>
Subject: RE: TK adv. White
You can affix John’s signature.
Thanks, Lynn

Lynn Shoen | A orney
P: 702.570.0000 | C: 702-380-8981 | F: 702.485.5266 | Direct: 702-380-8981
Downtown Las Vegas, NV: 710 S. 4th Street, Las Vegas, NV 89101

Offices: Summerlin, NV: 9455 W. Russell Road, Suite 100, Las Vegas, NV 89148
Reno, NV:338 Ryland Street, Reno, NV 89501

www.shookandstone.com |
"A Referral is the best compliment you could ever give our law firm. If you know someone who needs our ser
vices, please don't hesitate to tell them about us."
Personal Injury | Auto Accidents |Workers' Compensa on | Social Security Disability | Class Ac on | Accident Injury | Premises Liability | Medical Malprac ce
CONFIDENTIALITY NOTE:
The information contained in this email message is legally privileged and confidential information intended only for the use of the individual or entity to whom it is addressed.
If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this message is strictly prohibited.
If you have received this email in error, please immediately notify us by telephone, fax, or email and delete the message. Thank you.

From: Rebecca Mecham <[e-mail]>
Sent: Thursday, November 9, 2023 1:05 PM
To: Rebecca Mastrangelo <[e-mail]>; Lynn Shoen <[e-mail]>; Kiana A. O'Day
<KO'[e-mail]>; John Shook <[e-mail]>
Cc: Kathy Vigil <[e-mail]>; Rebecca Mecham <[e-mail]>
Subject: RE: TK adv. White

Rebecca Mecham
Paralegal
From: Rebecca Mastrangelo <[e-mail]>
Sent: Thursday, November 9, 2023 12:56 PM
To: Lynn Shoen <[e-mail]>; Rebecca Mecham <[e-mail]>; Kiana A. O'Day
<KO'[e-mail]>; John Shook <[e-mail]>
Cc: Kathy Vigil <[e-mail]>
Subject: RE: TK adv. White
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Sure thing.
Becki – please revise and send it back to Lynn for approval.
Thanks, everyone.
From: Lynn Shoen <[e-mail]>
Sent: Thursday, November 9, 2023 12:52 PM
To: Rebecca Mecham <[e-mail]>; Kiana A. O'Day <KO'[e-mail]>; John Shook
<[e-mail]>
Cc: Rebecca Mastrangelo <[e-mail]>; Kathy Vigil <[e-mail]>
Subject: RE: TK adv. White
Hello Rebecca
Please put in 10 days to file Reply.
Thanks, Lynn

Lynn Shoen | A orney
P: 702.570.0000 | C: 702-380-8981 | F: 702.485.5266 | Direct: 702-380-8981
Downtown Las Vegas, NV: 710 S. 4th Street, Las Vegas, NV 89101

Offices: Summerlin, NV: 9455 W. Russell Road, Suite 100, Las Vegas, NV 89148
Reno, NV:338 Ryland Street, Reno, NV 89501

www.shookandstone.com |
"A Referral is the best compliment you could ever give our law firm. If you know someone who needs our ser
vices, please don't hesitate to tell them about us."
Personal Injury | Auto Accidents |Workers' Compensa on | Social Security Disability | Class Ac on | Accident Injury | Premises Liability | Medical Malprac ce
CONFIDENTIALITY NOTE:
The information contained in this email message is legally privileged and confidential information intended only for the use of the individual or entity to whom it is addressed.
If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copy of this message is strictly prohibited.
If you have received this email in error, please immediately notify us by telephone, fax, or email and delete the message. Thank you.

From: Rebecca Mecham <[e-mail]>
Sent: Thursday, November 9, 2023 12:24 PM
To: Lynn Shoen <[e-mail]>; Kiana A. O'Day <KO'[e-mail]>
Cc: Rebecca Mecham <[e-mail]>; Rebecca Mastrangelo <[e-mail]>; Kathy Vigil
<[e-mail]>
Subject: TK adv. White
Counsel,
A ached is a dra S pula on and Order to Extend Time to File Opposi on and Reply. Please let me know what reply
deadline to insert in the S pula on.
If the stipulation meets with your approval, please provide your authorization to utilize your e-signature for submission
to the Court.
Thank you,

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Rebecca Mecham, Paralegal to
Stephen H. Rogers, Esq.
Rebecca L. Mastrangelo, Esq.
William C. Mitchell, Esq.
and Kerry O. Pluck, Esq.
Rogers, Mastrangelo, Carvalho & Mitchell, Ltd.
700 S. 3rd Street
Las Vegas, Nevada 89101
(P) [phone]
(F) [phone]
E-Mail: [e-mail]
Notice of Confidentiality:
This e-mail, and any attachment herewith, is intended only for use by the addressee(s) named herein and may contain legally privileged
and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination,
distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error,
please immediately notify me by e-mail (by replying to this message) or telephone (noted below) and permanently delete the original
and any copy of any e-mail and any printout thereof. Thank you for your assistance. Telephone number: [phone].

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