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 1 through 25, (THIRD 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., □□□□□□□ Milton, that Plaintiffs shall have an extension to March 25, 2021 to file a response to Defendant’ Motion to Dismiss.

20 This Stipulation is submitted and based upon the following: 21 1. On February 12, 2021, Defendant filed a motion to dismiss. [ECF No. 15].

22 2. Plaintiff's counsel fell ill on or around March 7, 2021 and the illness laste: approximately 6 days.

24 3. Plaintiff's counsel has almost finished Plaintiffs’ response in opposition t Defendant’s motion to dismiss; however, Mr. Huber had an unexpected family emergency tha arose on March 23, 2021.

2 □□ . .

4. Plaintiffs’ counsel reached out to Defense counsel who graciously agreed to stipulat to an additional three days to file Plaintiffs’ opposition.

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

2 6. As such, Defendant seeks a commensurate amount of additional time, through an || including April 20, 2021 to file a reply.

4 7. This is the third request for an extension of time.

5 || Dated this 23" day of March 2021.

RICHARD HARRIS LAW FIRM JACKSON LEWIS P.C. /s/ Burke Huber /s/ Kirsten _A. Milton 8 Richard Harris, Bar No. 505 Kirsten A. Milton, Bar No. 14401 9 Benjamin Cloward, Bar No. 11087 300 S. Fourth Street, Ste. 900 Burke Huber, Bar No. 10902 Las Vegas, Nevada 89101 10 801 S. Fourth Street Las Vegas, Nevada 89101 Attorneys for Defendant 11 Attorney for Plaintiffs Landry’s Inc. || ORDER IT IS SO ORDERED: RICHA LWARE, II || United States District Court || DATED this 24th day of March, 2021.