MOTION TO EXTEND TIME FOR DISPOSITIVE MOTIONS

(Second Request)

CAM FERENBACH, Magistrate Judge.

Plaintiffs, THE BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS HEALTH AND WELFARE TRUST; THE BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS JOINT PENSION TRUST; THE BOARD OF TRUSTEES OF THE CONSTRUCTION INDUSTRY AND LABORERS VACATION TRUST; THE BOARD OF TRUSTEES OF SOUTHERN NEVADA LABORERS LOCAL 872 TRAINING TRUST (hereinafter "Trustees"), by and through their counsel of record, The Urban Law Firm, pursuant to Local Rule 6.1, hereby move for an order to extend the dispositive motion deadline for forty-five (45) days. Currently, dispositive motions are due by February 4, 2016. (Dkt. #45). This would extend that deadline to March 21, 2016.

In late January, the Trustees approved the final terms of a settlement agreement involving SSWS and Mr. Ehrnreiter, and undersigned counsel forwarded a copy to Mr. Ehrnreiter for review. See Declaration of Seth T. Floyd ("Floyd Decl.") at ¶¶ 5-6, attached as Exhibit 1. A forty-five (45) day extension from February 4, 2016, to March 21, 2016, is therefore requested due to the pending settlement agreement between the parties. There will be no prejudice to Mr. Ehrnreiter, or any other party, from this extension and it will conserve judicial resources by avoiding the need for unnecessary dispositive motions.

Plaintiffs thus respectfully request that this Court extend the deadline to file dispositive motions.

IT IS SO ORDERED.

Exhibit 1

I, Seth T. Floyd, declare and state as follows:

1. I am an Associate with The Urban Law Firm and I am duly licensed to practice law in the State of Nevada and before this U.S. District Court. I am counsel of record for the Plaintiffs and I am the attorney responsible for the prosecution of this action.

2. I make this Declaration in support of the Plaintiffs' Motion To Extend Time For Dispositive Motions.

3. I make all statements in this Declaration based upon my personal knowledge unless stated otherwise herein.

4. As this Court can see from the docket in this case, this matter has a long and tortured history. However, over the last two months, the Trust Funds and Mr. Ehrnreiter have been negotiating the terms of a settlement agreement to resolve these claims.

5. On or around January 26, 2016, the trustees of the Trust Funds approved the final terms of a settlement agreement. I had previously discussed these terms directly with Mr. Ehrnreiter and he agreed to them in principle.

6. On or around February 1, 2016, I sent a written settlement agreement to Mr. Ehrnreiter for his final review. We have since been in contact about the agreement and Mr. Ehrnreiter is in the process of reviewing the terms.

7. Because of these ongoing settlement negotiations, it would not be prudent for any of the parties to submit dispositive motions unless and until settlement discussions are unsuccessful.

8. To accomplish the extension, I e-mailed Mr. Ehrnreiter a proposed stipulation on February 3, 2016, and I called and left a voicemail at approximately 12:30 p.m. on February 4, 2016. I am filing this motion because I have been unable to confer directly with Mr. Ehrnreiter on this matter, though I do not expect any objection.

9. There will be no harm or prejudice to Mr. Ehrnreiter from this extension because it will give both parties more time to resolve this matter. In fact, this will benefit Mr. Ehrnreiter as he may avoid having to respond to a motion for summary judgment.

10. Accordingly, I respectfully request that this Court grant a second extension of the time to file dispositive motions, currently due on February 4, 2016.

I declare under penalty of perjury under the laws of the United States and the State of Nevada that the foregoing is true and correct, and if called as a witness, I could and would competently testify thereto.

Executed at Las Vegas, Nevada on this 4st day of February, 2016.