JOINT STATUS REPORT RE CAESARS BANKRUPTCY PROCEEDINGS AND ORDER

ANDREW P. GORDON, District Judge.

Plaintiffs, Trustees of the Nevada Resort Association — International Alliance of Theatrical Stage Employees and Moving Picture Machine Operators of the United States and Canada, Local 720, Pension Trust; Trustees of the Nevada Resort Association — International Alliance of Theatrical Stage Employees and Moving Picture Machine Operators of the United States and Canada, Local 720, Wage Disability Trust; and Trustees of the Nevada Resort Association — International Alliance of Theatrical Stage Employees and Moving Picture Machine Operators of the United States and Canada, Local 720, Apprentice and Journeyman Training and Education Trust (collectively, "Plaintiffs" or "Trusts"), by and through their counsel of record, The Urban Law Firm, and Defendants Harrah's Las Vegas, LLC; Flamingo Las Vegas Operating Company, LLC; Desert Palace, Inc.; Paris Las Vegas Operating Company, LLC; and Parball Corporation (collectively "Defendants") by and through their counsel of record, Littler Mendelson, file this Joint Status Report in response to the Court's Order directing the same (Doc. No. 70):

1. The Parties agree that this matter shall be stayed with respect to Desert Palace, Inc., until further Order of this Court or until the automatic stay is lifted by the Bankruptcy Court.

2. The Parties further agree that Parball Corporation is a debtor entity included in the Caesars Entertainment Operating Company ("CEOC") Bankruptcy. Accordingly, this matter should be stayed with respect to Parball Corporation until further Order of this Court or until the automatic stay is lifted by the Bankruptcy Court. The Parties also agree that Plaintiffs will submit (and Defendants will not oppose) a Motion to Amend their Complaint to add Parball NewCo, LLC as a defendant. Plaintiffs will submit this request within fourteen (14) days of the entry of this Order.

3. Thus, the Parties agree that this matter should proceed with regard to Harrah's Las Vegas, LLC, Flamingo Operating Company, LLC, Paris Las Vegas Operating Company, and (if approved by the Court) Parball NewCo, LLC.

4. Additionally, prior to the CEOC Bankruptcy, Plaintiffs filed a Motion for Summary Judgment on November 20, 2014 (Doc. # 60), and Defendants opposed it (Doc. # 63) and also moved to strike the Declaration of Glenn Goodnough (Doc. # 64). Through those pleadings, and through discussions among counsel since that time, it has become apparent to both parties that additional discovery is warranted in this case. As a result, the Parties stipulate that docket numbers 60, 63 and 64 be withdrawn without prejudice. The Parties will be submitting a more detailed and specific Joint Motion to Re-Open Discovery contemporaneously herewith. Said Joint Motion will also include future dates for re-submitting any dispositive motions, if they are necessary after additional discovery is completed.

ORDER

This matter is hereby stayed as to Parball Corporation until further Order of this Court.

Plaintiffs shall have until fourteen days from the date of this Order to submit their Motion to Amend their Complaint to include Parball NewCo, LLC.

Plaintiffs' Motion for Summary Judgment, Defendants' Response to Plaintiffs' Motion for Summary Judgment and Defendants' Counter-Motion to Strike the Declaration of Glenn Goodnough (Doc. Nos. 60, 63 and 64, respectively) are hereby withdrawn without prejudice.

IT IS SO ORDERED.