Vasquez v. Gibraltar Hospitality Services, LLC

Filing 19

ORDER granting 18 Stipulation to Extend Time to File Settlement Paperwork. Settlement documents are due by 11/27/2023. Signed by Judge Cristina D. Silva on 11/13/2023. (Copies have been distributed pursuant to the NEF - CT)

1
2
3
4
5
6
7
8

Christian Gabroy
Nev. Bar No. 8805
Kaine Messer
Nev. Bar No. 14240
GABROY | MESSER
The District at Green Valley Ranch
170 South Green Valley Parkway
Suite 280
Henderson, Nevada 89012
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
Douglas Vasquez
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9

GABROY | MESSER

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

10
11

DOUGLAS VASQUEZ, individually and
on behalf of all others similarly situated,

12

Plaintiff

STIPULATION AND ORDER TO
EXTEND TIME TO FILE
SETTLEMENT PAPERWORK

GIBRALTAR HOSPITALITY
SERVICES, LLC d/b/a and a/k/a 7TH
AND CARSON;
EMPLOYEE(S)/AGENT(S) DOES 1-10;
and ROE CORPORATIONS 11-20;
inclusive,
Defendant

(First Request)

vs.

13
14
15
16
17

Case No. 2:23-cv-00441-CDS-DJA

18
19

Plaintiff Douglas Vasquez (“Plaintiff” or “Vasquez”) and Defendant Gibraltar

20

Hospitality Services, LLC d/b/a and a/k/a 7th and Carson (“Defendant”) (together

21

the “Parties”), by and through their respective counsel of record, hereby stipulate

22

and

23

including November 27, 2023 to file their proposed settlement and motion for

24

preliminary approval of class action settlement. This is the Parties’ first request

25

for such an extension.

26
27

respectfully

request

a

fourteen

(14)

day

extension

up

to

and

In support of this request, the Parties provide the following information
for the Court’s consideration:

28
Page 1 of 3

1.

1
2

advising the Court that the parties were preparing and exchanging appropriate

3

settlement paperwork and anticipated thereafter seeking approval of such class

4

action settlement pursuant to Rule 23(e) of the Federal Rules of Civil Procedure

5

and our law. See ECF No. 16.
2.

6

proposed settlement along with a motion for preliminary approval of class action

8

settlement on or before November 13, 2023. See ECF No. 17.

10

3.

The parties have been diligently working together in good faith

regarding such requisite settlement paperwork.
4.

11

GABROY | MESSER

On October 30, 2023, this Court ordered Plaintiff to submit a

7

9

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

On October 11, 2023, the Parties filed their Notice of Settlement

Specifically, the parties have exchanged their draft Joint Stipulation

12

of Settlement and Release with corresponding proposed exhibits thereto.

13

Defendant is currently reviewing the extensive documentation and the parties

14

anticipate circulating the documents for final approval and signature following such

15

review.
5.

16
17

Further, the parties have also diligently drafted, exchanged, and

executed settlement paperwork in their separate NLRB matter.

18

To complete such necessary review and achieve finalization of the

19

settlement paperwork, including the anticipated motion for preliminary approval of

20

class action settlement, the Parties respectfully request a fourteen (14) day

21

extension, up to and including November 27, 2023, to file the proposed settlement

22

along with a motion for preliminary approval of class action settlement.

23

///

24
25
26
27
28
Page 2 of 3

1
2

This stipulation is made in good faith, not for purposes of delay or burden,
and pursuant to our Rules. Not parties are prejudiced by this Stipulation.

3

Respectfully submitted this 13th day of November 2023.

4

GABROY | MESSER

FISHER & PHILLIPS LLP

5

By: /s/ Christian Gabroy
Christian Gabroy, Esq.
Kaine Messer, Esq.
The District at Green Valley Ranch
170 South Green Valley Parkway
Suite 280
Henderson, NV 89012
Tel: [phone]
[e-mail]
[e-mail]

By: /s/ David B. Dornak
David B. Dornak, Esq.
Allison L. Kheel, Esq.
300 South Fourth Street
Suite 1500
Las Vegas, NV 89101
Tel: [phone]
[e-mail]
[e-mail]

Attorney for Plaintiff Douglas Vasquez

Attorneys for Defendants Gibraltar
Hospitality Services LLC d/b/a and a/k/a
7th and Carson

6
7
8
9
10
11

GABROY | MESSER

170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

12
13
14
15

IT IS SO ORDERED:

16
17
18
19

______________________________
UNITED STATES DISTRICT JUDGE
November 13, 2023
Dated: ________________________

20
21
22
23
24
25
26
27
28
Page 3 of 3