Legar v. Landry's Inc dba Golden Nugget

1 || Burke Huber Nevada State Bar No. 10902 || RICHARD HARRIS LAW FIRM 801 South 4" Street || Las Vegas, Nevada 89101 Tel: (702) 444-4444 || Email: [email protected] Attorneys for Plaintiffs 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA || RITA LEGER, individually, RAYMOND ALLEN, individually, DIYANA |} VALKANOVA, individually, CHRISTINE Case No. 2:20-cv-02274-RFB-NJK CHENH, individually, ANTHONY DICH, || individually and on behalf of other members of the general public similarly situated, Plaintiff, STIPULATION TO EXTEND 12 DEADLINE FOR PLAINTIFF TO FILE VS. RESPONSE TO DEFENDANT’S 13 MOTION TO DISMISS LANDRY’S INC. dba GOLDEN NUGGET, || and DOES | through 25, (FIRST REQUEST) 15 Defendants.

16 IT IS HEREBY STIPULATED by and between Plaintiffs, through counsel Burke Huber, a M7 the Richard Harris Law Firm, and Defendant, through its counsel Jackson Lewis P.C., Kirstet Milton, that Plaintiffs shall have an extension to March 16, 2021 to file a response to Defendant’ Motion to Dismiss Plaintiffs’ first amended complaint.

20 This Stipulation is submitted and based upon the following: 1 1. On February 12, 2021, Defendant filed a motion to dismiss Plaintiffs’ first amendes complaint. [ECF No. 15].

23 2. In accordance with Local Rule 7-2((b), Plaintiffs’ response is currently due Februar 26, 2021.

25 3. Plaintiffs’ counsel is still homeschooling 3 children and this has caused significan delays in his ability to respond to motions within the ordinary 14 day allotted time.

2 4. In addition, Plaintiffs’ counsel’s firm recently switched to a new case managemen software and this has led to complete files missing, misplaced and uncalendared. l 5. Plaintiffs seek an additional time, through and including March 16, 2021, to file thei || response.

3 6. As such, Defendant seeks a commensurate amount of additional time, through an ||including April 9, 2021, to file its reply.

5 7. This request is made in good faith and not for the purpose of delay.

6 8. This is the first request for an extension of time.

7 || Dated this 26" day of February 2021.

RICHARD HARRIS LAW FIRM JACKSON LEWIS P.C. /s/ Burke Huber /s/ Kirsten A. Milton 10 Richard Harris, Bar No. 505 Kirsten A. Milton, Bar No. 14401 Benjamin Cloward, Bar No. 11087 300 S. Fourth Street, Ste. 900 Burke Huber, Bar No. 10902 Las Vegas, Nevada 89101 12 801 S. Fourth Street Las Vegas, Nevada 89101 Melisa H. Panagakos (pro hac vice) 13 Attorney for Plaintiffs 950 17th Street Suite 2600 14 Denver, CO 80202 Attorneys for Defendant || ORDER || IT IS SO ORDERED: RICHA As LWARE, Il || United States District Court || DATED this 26th day of February, 2021.