Cruz de Ramirez v. Cardenas Markets, LLC

Nevada Bar No. 7434

JOSEPH J. WIRTH, ESQ.

Nevada Bar No. 10280

ASH MARIE BLACKBURN, ESQ.

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

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA

JUANA A. CRUZ DE RAMIREZ, an CASE NO.: 2:19-cv-00814-RFB-BNW individual,

Plaintiff vs. [PROPOSED] STIPULATION AND

ORDER TO EXTEND JOINT PRETRIAL

CARDENAS MARKETS, LLC aka ORDER DEADLINE (SECOND

CARDENAS, a foreign limited liability REQUEST) company; LAMANZA LLC, a domestic limited liability company; DOE

MAINTENANCE COMPANY 1-10; DOE

INDIVIDUALS 1-20; and ROE BUSINESS

ENTITIES 1-20, inclusive,

Defendants

Pursuant to LR IA 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 explained below.

A. Reasons For the Extension

On March 22, 2021 a hearing was held regarding Defendant’s Motion for Summary Judgment which was subsequently denied. The courts ordered that the parties submit their Joint Pretrial Order within thirty (30) days of said ruling. Recently, counsel conferred regarding an additional time is needed in order to fully and properly identify portions of deposition transcripts intended to be used at the time of trial and provide objections regarding the same. Additionally, the parties are tentatively scheduled for mediation on June 7, 2021 in order to participate in meaningful negotiations.

As such, the May 13, 2021 deadline should be extended so that the parties are able to provide a proper Joint Pretrial Order to the Court and participate in meaningful settlement negotiations.

B. Proposed Revised Pretrial Order Schedule

The Joint Pretrial Order is due on May 13, 2021 and the parties are requesting the deadline be moved to June 18, 2021. This request for an extension of time is not sought for any improper purpose or other purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient time to adequately prepare their pretrial order to include portions of depositions in which the parties intend to use at the time of trial. Additionally, the extension of time will allow the parties to participate in meaningful settlement negotiations through mediation. The parties respectfully submit that the reasons set forth above constitute compelling reasons and good cause for the short extension.

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 13th day of April, 2021. DATED this 13th 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 % MAINOR WIRTH, LLP ao ll 6018 S. Fort Apache Road, Ste. 150

Las Vegas, NV 89148-5652

A 12 || Counsel for Plaintiff

(15

ORDER gat 7 IT IS SO ORDERED.

DATED this 18th day of May, 2021.

S

RICHA LWARE, II United States District Court