Filed: Jun. 03, 2019
Latest Update: Jun. 03, 2019
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR PLAINTIFFS TO FILE RESPONSE TO MOTION TO DISMISS (FIRST REQUEST) ANDREW P. GORDON , District Judge . Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR PLAINTIFFS TO FILE RESPONSE TO MOTION TO DISMISS (FIRST REQUEST) ANDREW P. GORDON , District Judge . Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline f..
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STIPULATION AND ORDER FOR EXTENSION OF TIME FOR PLAINTIFFS TO FILE RESPONSE TO MOTION TO DISMISS
(FIRST REQUEST)
ANDREW P. GORDON, District Judge.
Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline for Plaintiffs to file their response to Defendant's Motion to Dismiss (ECF No. 21) and state as follows:
1. On May 22, 2019, Defendant filed its Motion to Dismiss (the "Motion") (ECF No. 21).
2. Plaintiffs' response to the Motion is currently due on June 5, 2019.
3. Plaintiffs have requested 14 additional days to respond to the Motion and Defendant has agreed to grant such additional time.
4. Good cause exists to grant this extension, as trial counsel for Plaintiffs is currently engaged in trial efforts out-of-state and furthermore the Motion raises complex, potentially dispositive issues of law.
5. This stipulation is brought in good faith by both parties and not for purposes of delay. This extension will not result in undue delay in in the administration of this case.
6. No extension of time or continuance has previously been requested by Plaintiffs with respect to the Motion.
IT IS THEREFORE STIPULATED by and among the parties that the deadline for Plaintiffs to file a response to the Motion is extended up to and including June 19, 2019.
Respectfully submitted this 31st day of May, 2019.
/s/Kaine M. Messer /s/Travis F. Chance
CHRISTIAN J. GABROY, ESQ. MICHAEL A. FREIMANN, ESQ.
KAINE M. MESSER, ESQ. (admitted Pro Hac Vice)
MARTINE T. WELLS, ESQ.
JON R. MOWER, ESQ. (admitted Pro Hac Vice)
THEODORA ORINGHER PC TRAVIS F. CHANCE, ESQ.
Attorneys for Plaintiffs Attorneys for Defendant Wynn Las Vegas, LLC
IT IS SO ORDERED.