Cruz de Ramirez v. Cardenas Markets, LLC ( 2021 )

Nevada Bar No. 7434 2 JOSEPH J. WIRTH, ESQ. Nevada Bar No. 10280 3 ASH MARIE BLACKBURN, ESQ. 4 Nevada Bar No. 14712 MAINOR WIRTH, LLP 5 6018 S. Fort Apache Road, Ste. 150 Las Vegas, NV 89148-5652 6 Tel: (702) 464-5000 Fax: (702) 463-4440 7 ash@mwinjury.com 8 Counsel for Plaintiff 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 JUANA A. CRUZ DE RAMIREZ, an CASE NO.: 2:19-cv-00814-RFB-BNW 12 individual, Plaintiff 13 vs. [PROPOSED] STIPULATION AND ORDER TO EXTEND JOINT PRETRIAL 14 CARDENAS MARKETS, LLC aka ORDER DEADLINE (SECOND 15 CARDENAS, a foreign limited liability REQUEST) company; LAMANZA LLC, a domestic 16 limited liability company; DOE MAINTENANCE COMPANY 1-10; DOE 17 INDIVIDUALS 1-20; and ROE BUSINESS ENTITIES 1-20, inclusive, 18 19 Defendants 20 Pursuant to LR IA 6-1, the parties, by and through their respective counsel of record, 21 hereby stipulate and request that this Court extend the Joint Pretrial Order deadline in the above- 22 captioned matter. Good cause exists to extend the remaining deadline for the reasons explained 23 below. 24 A. Reasons For the Extension 25 On March 22, 2021 a hearing was held regarding Defendant’s Motion for Summary 26 Judgment which was subsequently denied. The courts ordered that the parties submit their Joint 27 Pretrial Order within thirty (30) days of said ruling. Recently, counsel conferred regarding an 28 2 additional time is needed in order to fully and properly identify portions of deposition transcripts 3 intended to be used at the time of trial and provide objections regarding the same. Additionally, 4 the parties are tentatively scheduled for mediation on June 7, 2021 in order to participate in 5 meaningful negotiations. 6 As such, the May 13, 2021 deadline should be extended so that the parties are able to 7 provide a proper Joint Pretrial Order to the Court and participate in meaningful settlement 8 negotiations. 9 B. Proposed Revised Pretrial Order Schedule 10 The Joint Pretrial Order is due on May 13, 2021 and the parties are requesting the deadline 11 be moved to June 18, 2021. This request for an extension of time is not sought for any improper 12 purpose or other purpose of delay. Rather, it is sought by the parties solely for the purpose of 13 allowing sufficient time to adequately prepare their pretrial order to include portions of 14 depositions in which the parties intend to use at the time of trial. Additionally, the extension of 15 time will allow the parties to participate in meaningful settlement negotiations through mediation. 16 The parties respectfully submit that the reasons set forth above constitute compelling reasons and 17 good cause for the short extension. 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 1 WHEREFORE, the parties respectfully request that this Court extend the deadline fo 2 || submitting their Joint Pretrial Order from the current deadline as outlined above. 3 || DATED this 13th day of April, 2021. DATED this 13th day of April, 2021. 4 || MAINOR WIRTH, LLP WILSON ELSER MOSKOWITZ EDELMAN & DICKER, LLP 6 /s/ Ash Marie Blackburn /s/ Michael Lowry 7 || BRADLEY S. MAINOR, ESQ. MICHAEL P. LOWRY, ESQ. Nevada Bar No. 7434 Nevada Bar No. 10666 8 || JOSEPH J. WIRTH, ESQ. 300 South 4" Street, 11" Floor Nevada Bar No. 10280 Las Vegas, NV 89101-6014 9 | ASH MARIE BLACKBURN, ESQ. Counsel for Defendants 10 Nevada Bar No. 14712 % MAINOR WIRTH, LLP ao ll 6018 S. Fort Apache Road, Ste. 150 Las Vegas, NV 89148-5652 A 12 || Counsel for Plaintiff 28 13 14 (15 ORDER gat 7 IT IS SO ORDERED. DATED this 18th day of May, 2021. 3 18 20 19 S 20 RICHA LWARE, II United States District Court 22 23 24 25 26 27 28 Page 3 of 3