Thomas v. Foundever Operating Corporation

Filing 14

ORDER Granting #13 Stipulation to Continue Early Neutral Evaluation. The Early Neutral Evaluation scheduled for April 28, 2025 is VACATED and RESET for May 19, 2025 at 10:00 a.m. IT IS FURTHER ORDERED that the written evaluation statements are due by 4:00 p.m. on May 12, 2025. IT IS FURTHER ORDERED that all other provisions of the Court's order (ECF No. #9 ) shall remain in effect. Early Neutral Evaluation set for 5/19/2025 at 10:00 AM in LV Courtroom 3A before Magistrate Judge Daniel J. Albregts. Signed by Magistrate Judge Daniel J. Albregts on 3/11/2025. (Copies have been distributed pursuant to the NEF - RJDG)

1
2
3
4
5
6
7
8

Kathryn L. Bain, State Bar No. 15496
BAIN MAZZA & DEBSKI LLP
10300 W. Charleston Blvd., Ste. 13-191
Las Vegas, NV 89135
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
JASHYUA THOMAS
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9
10
11
12
13
14
15
16
17
18

JASHYUA THOMAS, an individual,

)
)
)
Plaintiff,
)
)
vs.
)
)
FOUNDEVER OPERATING
CORPORATION, a corporation, and DOES )
)
1-50, inclusive,
)
)
Defendants.
)
)
)
)
)
)
_____________________________________ )

Case No. 2:25-cv-152 -APG-BNW
STIPULATION TO RESCHEDULE
DATE OF EARLY NEUTRAL
EVALUATION
(FIRST REQUEST)

19
20
21
22
23
24
25
26
27
28
-1STIPULATION TO RESCHEDULE ENE DATE

Case No. 2:25-cv-152

1
2
3
4
5
6

Plaintiff JASHYUA THOMAS (“Plaintiff”) and Defendant FOUNDEVER OPERATING
CORPORATION (“Defendant”), by and through their undersigned counsel, hereby agree and
stipulate to reschedule the date for the Early Neutral Evaluation (ENE) in this matter, currently set for
April 28, 2025 at 10:00 a.m. with Magistrate Judge Daniel J. Albregts. Plaintiff’s counsel is unavailable
on the current date due to previously arranged travel plans. The Parties are both available on either May

7

19, 2025 or May 20, 2025, and propose these alternate dates for the ENE. If Judge Albregts is not

8

available on these dates, the Parties request that the ENE be rescheduled to another available date.

9
10
11
12
13

This is the first request to reschedule the ENE in this case. This request is made in good faith and
not for the purpose of delay.
Dated: March 10, 2025

Dated: March 10, 2025

Respectfully submitted,

Respectfully submitted,

/s/ Kathryn L. Bain
____________________________________
Kathryn L. Bain
Bain Mazza & Debski LLP
Attorneys for Plaintiff
Jashyua Thomas

/s/ Luke W. Molleck
___________________________________
Roger L. Grangenett II
Luke W. Molleck
Little Mendelson, P.C.
Attorneys for Defendant
Foundever Operating Corporation

14
15
16
17
18
19
20
21
22
23
24
25
26
27

IT IS SO ORDERED. The Early Neutral Evaluation scheduled
for April 28, 2025 is VACATED
IT IS SO ORDERED.
and RESET for May 19, 2025 at 10:00 a.m.
Dated: _____________________
IT IS FURTHER ORDERED that the written evaluation statements are due by 4:00 p.m. on
May 12, 2025.
IT IS FURTHER ORDERED that all other provisions of
the Court's order (ECF No. 9) shall
____________________________________
remain in effect.
DATED: 3/11/2025

____________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

28
-2STIPULATION TO RESCHEDULE ENE DATE

Case No. 2:25-cv-152