Cruz de Ramirez v. Cardenas Markets, LLC

1 || BRADLEY S. MAINOR, ESQ.

Nevada Bar No. 7434 2 || JOSEPH J. WIRTH, ESQ.

3 Nevada Bar No. 10280

ASH MARIE BLACKBURN, ESQ.

4 || Nevada Bar No. 14712

MAINOR WIRTH, LLP 5 || 6018 S. Fort Apache Road, Ste. 150

Las Vegas, NV 89148-5652 © | Tel: (702) 464-5000 7 || Fax: (702) 463-4440 [email protected] 8 || Counsel for Plaintiff 9 UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA a 11 2 JUANA A. CRUZ DE RAMIREZ, an | CASENO.: 2:19-cv-00814-RFB-BNW ZY 12 individual, 4 Plaintiff

13 | vs. [PROPOSED] STIPULATION AND 8 4 ORDER TO EXTEND JOINT PRETRIAL & CARDENAS MARKETS, LLC aka | ORDER DEADLINE (FIRST REQUEST) 45 || CARDENAS, a foreign limited liability

& S company; LAMANZA LLC, a domestic “16 || limited liability company; DOE 2 MAINTENANCE COMPANY 1-10; DOE 28 17 || INDIVIDUALS 1-20; and ROE BUSINESS

ENTITIES 1-20, inclusive, 19 Defendants

S © 20 Pursuant to LR JA 6-1, the parties, by and through their respective counsel of record 21 || hereby stipulate and request that this Court extend the Joint Pretrial Order deadline in the above 22 || captioned matter. Good cause exists to extend the remaining deadline for the reasons explaines 93 +H below.

24 A. Reasons For the Extension 25 On March 22, 2021 a hearing was held regarding Defendant’s Motion for Summar 26 || Judgment which was subsequently denied. The courts ordered that the parties submit their Joir 27 || Pretrial Order within thirty (30) days of said ruling. Recently, counsel conferred regarding a

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1 || extension of time to submit the parties’ Joint Pretrial Order in this case. Counsel agree tha 2 || additional time is needed in order to fully and properly identify portions of deposition transcript 3 || intended to be used at the time of trial and provide objections regarding the same. 4 As such, the April 22, 2021 deadline should be extended so that the parties are able t 5 || provide a proper Joint Pretrial Order to the Court.

6 B. Proposed Revised Pretrial Order Schedule 7 The Joint Pretrial Order is due on April 22, 2021 and the parties are requesting th 8 || deadline be moved to May 13, 2021. This request for an extension of time is not sought for an 9 || improper purpose or other purpose of delay. Rather, it is sought by the parties solely for th 10 || purpose of allowing sufficient time to adequately prepare their pretrial order to include portions o 11 || depositions in which the parties intend to use at the time of trial. The parties respectfully subm:

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12 |) that the reasons set forth above constitute compelling reasons and good cause for the shor & 13 || extension.

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20 | /// 21 | /// 22 | /// 23 |} /// 24 | /// 25 | /// 26 | /// 27 | /// 1 WHEREFORE, the parties respectfully request that this Court extend the deadline fo 2 || submitting their Joint Pretrial Order from the current deadline as outlined above. 3 |} DATED this 21st day of April, 2021. DATED this 21st_ day of April, 2021. 4 || MAINOR WIRTH, LLP WILSON ELSER MOSKOWITZ ; EDELMAN & DICKER, LLP 6 /s/ Ash Marie Blackburn /s/ Michael Lowry 7 || BRADLEY S. MAINOR, ESQ. MICHAEL P. LOWRY, ESQ.

Nevada Bar No. 7434 Nevada Bar No. 10666 8 || JOSEPH J. WIRTH, ESQ. 300 South 4" Street, 11" Floor

Nevada Bar No. 10280 Las Vegas, NV 89101-6014 9 || ASH MARIE BLACKBURN, ESQ. Counsel for Defendants 10 Nevada Bar No. 14712

2 MAINOR WIRTH, LLP ll 6018 S. Fort Apache Road, Ste. 150

Las Vegas, NV 89148-5652 2 12 || Counsel for Plaintiff hb 5 14 = 15

ORDER

7 IT IS SO ORDERED.

DATED this 22nd _ day of April, 2021.

S

RICHA LWARE, II

United States District Court