Cruz de Ramirez v. Cardenas Markets, LLC

1 || BRADLEY S. MAINOR, ESQ.

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

3 Nevada Bar No. 10280 ASH MARIE BLACKBURN, ESQ.

4 || Nevada Bar No. 14712 MAINOR WIRTH, LLP || 6018 S. Fort Apache Road, Ste. 150 Las Vegas, NV 89148-5652 © | Tel: (702) 464-5000 || Fax: (702) 463-4440 [email protected] || 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 | vs. [PROPOSED] STIPULATION AND 8 4 ORDER TO EXTEND JOINT PRETRIAL & CARDENAS MARKETS, LLC aka | ORDER DEADLINE (FIRST REQUEST) || CARDENAS, a foreign limited liability & S company; LAMANZA LLC, a domestic “16 || limited liability company; DOE 2 MAINTENANCE COMPANY 1-10; DOE 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 || hereby stipulate and request that this Court extend the Joint Pretrial Order deadline in the above || captioned matter. Good cause exists to extend the remaining deadline for the reasons explaines +H below.

24 A. Reasons For the Extension 25 On March 22, 2021 a hearing was held regarding Defendant’s Motion for Summar || Judgment which was subsequently denied. The courts ordered that the parties submit their Joir || Pretrial Order within thirty (30) days of said ruling. Recently, counsel conferred regarding a Page | of 3 || extension of time to submit the parties’ Joint Pretrial Order in this case. Counsel agree tha || additional time is needed in order to fully and properly identify portions of deposition transcript || 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 || 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 || deadline be moved to May 13, 2021. This request for an extension of time is not sought for an || improper purpose or other purpose of delay. Rather, it is sought by the parties solely for th || purpose of allowing sufficient time to adequately prepare their pretrial order to include portions o || depositions in which the parties intend to use at the time of trial. The parties respectfully subm: > + |) that the reasons set forth above constitute compelling reasons and good cause for the shor & 13 || extension.

14 | ///

16 | /// | ww x 18 | /// 2 19 □□ /// S | /// | /// | /// |} /// | /// | /// | /// | /// Page 2 of 3 1 WHEREFORE, the parties respectfully request that this Court extend the deadline fo || 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 /s/ Ash Marie Blackburn /s/ Michael Lowry || BRADLEY S. MAINOR, ESQ. MICHAEL P. LOWRY, ESQ.

Nevada Bar No. 7434 Nevada Bar No. 10666 || JOSEPH J. WIRTH, ESQ. 300 South 4" Street, 11" Floor Nevada Bar No. 10280 Las Vegas, NV 89101-6014 || 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 12 || Counsel for Plaintiff hb 14 = 15 ORDER 7 IT IS SO ORDERED.

DATED this 22nd _ day of April, 2021.

S RICHA LWARE, II United States District Court Page 3 of 3