McKenzie v. Amazon.com Services LLC

Filing 33

ORDER Granting 32 Stipulation for Extension of Time re 27 Motion to Dismiss. Responses due by 8/5/2024. Signed by Judge Andrew P. Gordon on 6/3/2024. (Copies have been distributed pursuant to the NEF - RJDG)

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Wendy M. Krincek, Esq.
Nevada Bar No. 6417
Emil S. Kim, Esq.
Nevada Bar No. 14894
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway
Suite 300
Las Vegas, Nevada 89169.5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
[e-mail]
[e-mail]
Attorneys for Defendant
AMAZON.COM SERVICES LLC

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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ANNA “TASHA” MCKENZIE, an Individual,
Plaintiff,

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v.
AMAZON.COM SERVICES LLC, a foreign
limited liability company,

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Defendant.

Case No. 2:24-cv-00262-APG-NJK
JOINT NOTICE OF SETTLEMENT
AND STIPULATION TO EXTEND
TIME FOR PLAINTIFF’S RESPONSE
TO DEFENDANT’S PARTIAL MOTION
TO DISMISS PLAINTIFF’S FIRST
AMENDED COMPLAINT (3RD
REQUEST); ORDER

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PLEASE TAKE NOTICE that Plaintiff, by and through her counsel of record, HKM

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Employment Attorneys LLP, and Defendant, by and through its counsel of record, Littler

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Mendelson P.C., have reached an agreement for a full and final settlement of Plaintiff’s claims in

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this action. However, additional time is needed to finalize and review the settlement agreement and

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release.

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The Parties further stipulate and request approval from the Court that the date for Plaintiff

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to file an Opposition to Defendants’ Partial Motion to Dismiss (ECF No. 27) be extended by 60

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days, from June 4, 2024, to August 5, 2024, so Plaintiff is not unduly prejudiced. This would be

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the Parties’ 3rd request to extend Plaintiff’s deadline to file an Opposition to Defendants’ Partial

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Motion to Dismiss.

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Extending the deadline would be in the interests of conserving both private and judicial
resources, and to ensure that the settlement agreement currently in place is not jeopardized.

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The parties expect to submit to the Court a Stipulation and Order for Dismissal of the action

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upon execution of a formal settlement agreement. The parties are currently working on finalizing

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the terms of the written settlement agreement. The parties anticipate the Stipulation and Order to

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be submitted to the Court within 60 days and request that the proposed order attached as Exhibit A

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be issued by the Court.

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IT IS SO STIPULATED.
Dated: May 29, 2024
HKM EMPLOYMNET ATTORNEYS LLP

LITTLER MENDELSON, P.C.

/s/ Rebecca Rojas, Esq.
REBECCA ROJAS, ESQ.
DANA SNIEGOCKI, ESQ.

/s/ Wendy M. Krincek, Esq.
WENDY M. KRINCEK, ESQ.
EMIL S. KIM, ESQ.

Attorneys for Plaintiff
ANNA "TASHA" MCKENZIE

Attorneys for Defendant
AMAZON.COM SERVICES LLC

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IT IS SO ORDERED:

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June 3, 2024
Dated:__________________

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________________________
ANDREW P. GORDON
UNITED STATES DISTRICT JUDGE

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