Ballinger v. Prime Healthcare Services - Reno, LLC

Filing 10

ORDER granting ECF No. 9 Stipulation to Extend Time : Response to ECF No. 5 Partial Motion to Dismiss due by 5/24/2022. Signed by Chief Judge Miranda M. Du on 5/9/2022. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:22-cv-00084-MMD-CLB Document 10 Filed 05/09/22 Page 1 of 3

1 WILLIAM J. GEDDES
Nevada Bar No. 6984

2 KRISTEN R. GEDDES
Nevada Bar No. 9027

3 THE GEDDES LAW FIRM, P.C.
1575 Delucchi Lane, Suite 206

4 Reno, Nevada 89502

Phone: [phone]
5 Fax: [phone]
Email: [e-mail]
6 Email: [e-mail]
Attorney for Plaintiff Rebecca Ballinger

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

10 REBECCA BALLINGER,

The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

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CASE NO.: 3:22-cv-00084-MMD-CLB

Plaintiff,

12 vs.
13 PRIME HEALTHCARE SERVICES – RENO,

STIPULATION AND
PROPOSED ORDER FOR
ENLARGEMENT OF TIME

LLC, a Foreign Limited Liability Company,

14 dba St. Mary’s Regional Medical Center.
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For Plaintiff to File Response
To Defendant’s Partial Motion to Dismiss
Plaintiff’s Complaint

Defendant.

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(ECF 005)

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(First Request)

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The parties to this action, by and through their undersigned counsel of record hereby stipulate

20 that Plaintiff may have a two (2)-week extension of time, through and including Tuesday, May 24,
21 2022, to file her response to Defendant’s Partial Motion to Dismiss Plaintiff’s Complaint (ECF 005).
22 This is the first request for such an extension. The original deadline to file this opposition is Tuesday,
23 May 10, 2022. The reason Plaintiff needs additional time to file this brief is because her counsel has a
24 very congested calendar and was out of the office for much of last week, and he will need additional
25 time to prepare a responsive brief.
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Case 3:22-cv-00084-MMD-CLB Document 10 Filed 05/09/22 Page 2 of 3

1 This Stipulation is not offered for any dilatory or improper purpose.
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Dated this 9th day of May 2022.

Dated this 9th day of May 2022.

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LITTLER MENDELSON

THE GEDDES LAW FIRM, P.C.

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Electronic Signature Authorized

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The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

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By:

/s/
KARYN M. TAYLOR, ESQ.,
Nevada Bar Number 6142
[e-mail]
200 South Virginia Street, 8th Floor
Reno, NV 89501
Telephone: [phone]

WILLIAM J. GEDDES, ESQ.
Nevada Bar Number 6984
[e-mail]
1575 Delucchi Lane, Suite 206
Reno, Nevada 89502
[phone]

Attorneys for Defendant
Prime Healthcare Services – Reno, LLC

Attorney for Plaintiff Rebecca Ballinger

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ORDER

16 Dated: May 9, 2022

IT IS SO ORDERED

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UNITED STATES DISTRICT JUDGE

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Case 3:22-cv-00084-MMD-CLB Document 10 Filed 05/09/22 Page 3 of 3

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CERTIFICATE OF SERVICE
I hereby certify that I am an employee of the Geddes Law Firm, P.C., and that on May 9, 2022,

3 I caused to be served a copy of the foregoing Stipulation and Proposed Order for Enlargement of Time
4 for Plaintiff to File Response to Defendant’s Partial Motion to Dismiss Plaintiff’s Complaint (First
5 Request), by electronic filing with the Court’s Pacer e-filing system, addressed to:
6 KARYN M. TAYLOR, ESQ., Bar #6142
[e-mail]

7 LUCAS W. MOLLECK, ESQ., Bar #14405
[e-mail]

8 LITTLER MENDELSON

200 South Virginia Street, 8th Floor

9 Reno, NV 89501

Telephone: [phone]

10 Facsimile: [phone]
11 Attorneys for Defendant

Prime Healthcare Services – Reno, LLC

The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

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Dated this 9th day of May 2022.

THE GEDDES LAW FIRM, P.C

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WILLIAM J. GEDDES, ESQ.
Nevada Bar Number 6984
The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, Nevada 89502
[phone]
Attorney for Plaintiff Rebecca Ballinger

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