STIPULATION AND ORDER TO EXTEND TIME TO FILE DISPOSITIVE MOTIONS AND RESPONSES AND REPLIES THERETO

(FIRST REQUEST)

RICHARD F. BOULWARE, II, District Judge.

Pursuant to LR IA 6-1, LR IA 6-2, and LR 26-4, Plaintiff Sandy Bagsby ("Plaintiff") and Defendants Eldorado Resorts Corporation ("Eldorado"), Michael Marrs ("Marrs"), Kristen Hayde (formerly known as Beck) ("Hayde"), and Dominic Taleghani ("Taleghani") (collectively "Defendants"), by and through their undersigned counsel, hereby stipulate and agree to this first request for extension of time for the parties to file dispositive motions in this action, along with related responses and replies. Pursuant to the Court's March 31, 2017, Order for Extension of Discovery Deadlines (ECF No. 43), the current deadline for filing dispositive motions in this case is June 22, 2017. The parties have completed all discovery in this matter and good cause exists for the proposed extension based upon the following:

As the Court is aware, this case is one of over thirty related lawsuits sitting before this Court. Recognizing the complexity of litigating these lawsuits simultaneously, the parties agreed to divide the cases into five groups and stagger deadlines in order to streamline the litigation process and avoid overlapping dispositive motion deadlines. On March 30, 2017, the parties agreed to a comprehensive briefing schedule for dispositive motions in the remaining groups of cases. (ECF No. 42.) The current status of the comprehensive briefing schedule is as follows:

In compliance with that stipulation, Defendants filed Motions for Summary Judgment on February 27, 2017, in Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv-01026-RFB-PAL (ECF No. 60); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015-RFB-PAL (ECF No. 57); D. Parr v. Eldorado Resorts Corp., Case No.: 2:15-cv-01028-RFB-PAL (ECF No. 50); and Scheinberg v. Eldorado Resorts Corp., Case No.: 2:15-cv-01031-RFB-PAL (ECF No. 63). Unilaterally and without notice to defense counsel, on the day before oppositions were due, Plaintiffs filed a request for an extension to file oppositions to the Motions for Summary Judgment on March 28, 2017, in the foregoing cases: Barnes v. Eldorado Resorts Corp., Case No.: 2:15-cv-01026-RFB-PAL (ECF No. 63); Kaplan v. Eldorado Resorts Corp., Case No.: 2:15-cv-01015-RFB-PAL (ECF No. 60); D. Parr v. Eldorado Resorts Corp., Case No.: 2:15-cv-01028-RFB-PAL (ECF No. 53); and Scheinberg v. Eldorado Resorts Corp., Case No.: 2:15-cv-01031-RFB-PAL (ECF No. 66), seeking to extend the current filing date of March 29, 2017, to April 12, 2017. This request remains pending before the Court. Due to this delay, the entire comprehensive briefing schedule has been impacted, causing overlapping and unreasonable deadlines. The delays will make it difficult to comply with the current briefing schedules for the remaining matters.

Accordingly, the parties hereby stipulate to adjust the briefing schedule in the manner presented below in an effort to allow the parties to comply with the briefing schedule in a reasonable manner as follows:

As relevant to this matter, the parties have agreed that the dispositive motion deadlines should be extended as follows:

This stipulation is not brought for purposes of delay or any other improper purpose.

ORDER

IT IS SO ORDERED.