Hamilton v. 99 Cents Only Stores LLC

1 LEW BRANDON, JR., ESQ.

Nevada Bar No. 5880 || JEFFREY J. ORR, ESQ.

3 Nevada Bar No.: 7854 HOMERO GONZALEZ, ESQ.

4 Nevada Bar No.: 15231 BRANDON | SMERBER LAW FIRM || 139 East Warm Springs Las Vegas, Nevada 89119 (702) 380-0007 (702) 380-2964 — facsimile [email protected] [email protected] [email protected] Attorneys for Defendant, || 99 CENTS ONLY STORES LLC 11 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA ROCHELLE HAMILTON, individually, CASE NO.: 2:21-cv-01909-APG-EJY 15 Plaintiff, VS. || 99 CENTS ONLY STORES LLC., a Foreign Limited-liability Company; and DOES 1 18 through 20; and ROE BUSINESS ENTITIES through 20, 20 Defendants.

STIPULATION AND ORDER TO CONTINUE DEADLINE FOR PARTIES TO FILE JOINT PRE-TRIAL ORDER 74 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff ROCHELLI = HAMILTON, through her counsel of record, Samantha Martin, Esq. of RICHARD HARRI LAW FIRM, and Defendant 99 CENTS ONLY STORES LLC, through its counsel record, Lev □ Brandon, Jr., Esq, Jeffrey J. Orr, Esq. and Homero Gonzalez, Esq. of Brandon | Smerber Lav Firm, that the deadline to file the parties’ Joint Pre-Trial shall be continued to April 5, 2023.

Page |] of 2 ; The Joint Pre Trial order was due on November 21, 2022. However, this deadline wa: stayed upon Defendant’s filing of a dispositive motion, which was decided on December 2, 2022 As a result, the deadline for filing the Joint Pre-Trial Order is January 1, 2023. The purpose fo this request is that the parties have agreed to mediate this matter with Judge Gene Porter, Ret. o: ° Private Trials and have scheduled a mediation session for March 6, 2023. The parties intend tc meaningfully participate and mediate this matter in good faith. The parties also understand the Ilneed to complete this Joint Pre-Trial Order should this matter not resolve at mediation. At □ extension of time to file the Joint Pre-Trial Order will allow the parties to focus their efforts or ? resolving this matter at mediation. This request is not meant to cause undue delay. Therefore }l the parties respectfully request an extension of time to file the Joint Pre-Trial Order until 30 day: || after the mediation session, which is April 5, 2023.

7 IT IS SO STIPULATED.

14 ||DATED this 15" day of December 2022. = DATED this 15"" day of December 2022.

15 RICHARD HARRIS LAW FIRM BRANDON SMERBER LAW FIRM 17 /s/ Samantha Martin, Esq. /s/ Jeffrey J. Orr, Esq.

SAMANTHA A. MARTIN, ESQ. LEW BRANDON, JR., ESQ.

18 Nevada Bar No. 12998 Nevada Bar No. 5880 801 South 4" Street JEFFREY J. ORR, ESQ.

Las Vegas, Nevada 89101 Nevada Bar No.: 7854 || Attorney for Plaintiff HOMERO GONZALEZ, ESQ.

Rochelle Hamilton Nevada Bar No.: 15231 21 139 East Warm Springs Las Vegas, Nevada 89119 22 Attorneys for Defendant, 93 99 CENTS ONLY STORES LLC ORDER IT IS SO ORDERED.

27 || DATED: December 16, 2022 □ 28 UNITED 8TATE AGISTRATE JUDGE Page ? of 2