Singh v. Albertson's LLC ( 2024 )

1 JNaecvka Pd.a BSutartdee nB,a Er sNqo. . 6918 2 Jacquelyn Franco, Esq. Nevada State Bar No. 13484 3 BACKUS | BURDEN 4 3050 South Durango Drive Las Vegas, NV 89117 5 (702) 872-5555 (702) 872-5545 6 jburden@backuslaw.com jacquelynfranco@backuslaw.com 7 DallinKnecht@backuslaw.com 8 Attorneys for Defendant, Albertson’s LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 MACHELLE SINGH, individually, ) Case 2:23-cv-00436-APG-MDC ) 13 Plaintiff, ) STIPULATION AND ORDER TO vs. ) CONTINUE DEADLINE FOR 14 ) PROPOSED JOINT PRETRIAL ORDER ALBERTSON’S LLC d/b/a ALBERTSONS, a ) FOR 30 DAYS 15 foreign limited-liability company; DOES I ) 16 through X; and ROE CORPORATIONS I ) through X, inclusive ) 17 ) Defendants. ) 18 19 Plaintiff MACHELLE SINGH (“Plaintiff”), by and through her attorney of record, M. Erik 20 Ahlander, Esq. of the law firm AHLANDER INJURY LAW, and Defendant ALBERTSON’S LLC 21 (“Defendant”), by and through its attorneys of record, Jack P. Burden, Esq. and Jacquelyn Franco, 22 Esq. of the law firm of BACKUS | BURDEN, hereby stipulate and agree to an extension of the 23 deadline to file Proposed Joint Pretrial Order by thirty (30) days. 24 The Proposed Joint Pretrial Order is currently due to the Court by April 8, 2024. The 25 Parties are actively engaged in settlement negotiations. The requested extension will allow the 26 parties sufficient time to complete the negotiations or, if necessary, prepare and file the Joint 27 Pretrial Order. 28 Pursuant to LR IA 6-1(b), the Parties hereby aver that this is the first extension requested as it relates to the Joint Pretrial Order. Moreover, pursuant to Local Rule 26-3, it is respectfully 2 submitted the Parties’ failure to request the instant extension prior to the filing deadline was the 3 result of excusable neglect; specifically noting the failure to request the extension of was a mere 4 oversight by the Parties. Bateman v. U.S. Postal Service, 231 F.3d 1220 (9* Cir. 2000). Further: 1) there is no danger of prejudice as the extension is stipulated by the Parties; 2) a thirty (30) day 6 extension will not impact a trial date because the same has not been scheduled; 3) the Parties are 7 hopeful to attend a settlement conference within the requested extended period; and 4) the 8 requested extension is made in good faith by both Parties. Pioneer Investment Services v. ? Brunswick Associate’s, Ltd., 507 U.S. 380, 395 (1993). 10 As such, the Parties stipulate and agree to jointly ask the Court to extend the deadline to i submit the Proposed Joint Pretrial Order by 30 days to May 8, 2024. 12 IT IS SO STIPULATED. 13 14 DATED this 5th day of April, 2024. DATED this 5th day of April, 2024. 15 AHLANDER INJURY LAW BACKUS | BURDEN 16 /s/ M. Erik Ahlander /s/ Jack Burden M. Erik Ahlander, Esq. Jack P. Burden, Esq. Nevada Bar No. 9490 Nevada Bar No. 6918 18 9183W, Flamingo Rd., Ste. 110 Jacquelyn Franco, Esq. Las Vegas, Nevada 89147 Nevada Bar No. 13484 19 Counsel for Plaintiff 3050 South Durango Drive Las Vegas, Nevada 89117 20 Counsel for Defendant 21 22 ORDER 3 IT IS HEREBY ORDERED that the Parties shall submit the Proposed Joint Pretrial Order 24 || by May 8, 2024. The parties must comply with LR IA 6-1 for any future extensions or continuance: 25 IT IS SO ORDERED. poz 6 DATED: this 8th day of April 2024 ft ff Lf {f 27 fe hfe Tt Hoff. Maximiliatys D. Gouvillier II 28 United States Magistrate Judge