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Barnes v. Eldorado Resorts Corp.

United States District Court, D. Nevada

March 27, 2017

GAIL BARNES, Plaintiff;
v.
ELDORADO RESORTS CORPORATION, a Florida corporation; MICHAEL MARRS; KRISTEN BECK; DOMINIC TALEGHANI; AND DOES 1-50, inclusive; Defendants.

          WATKINS & LETOFSKY, LLP, DANIEL R. WATKINS, BRIAN S. LETOFSKY, ERAN S. FORSTER, WATKINS & LETOFSKY, LLP Attorneys for Plaintiff, GAIL BARNES

          PLAINTIFF'S REQUEST FOR AN EXTENTION TO FILE AN OPPOSITION TO THE MOTION FOR SUMMARY JUDGEMENT. [PLAINTIFF'S SECOND REQUEST FOR AN EXTENSION TO RESPOND TO DISPOSITIVE MOTIONS]

          RICHARD F. BOULWARE, II United States District Judge

         COMES NOW, Plaintiff, GAIL BARNES, by and through their attorney of record, hereby submits Plaintiff's Motion for Extension of Time to Respond to Dispositive Motions. This motion is made under the Federal Rule of Civil Procedure (hereinafter “FRCP”) rule 6(b)(1)(A) and Nevada District Court Local Rules (hereinafter “LR”) 6-2 and 26-4. Defendant filed their Motion for Summary Judgment on February 27, 2017. The current deadline for Plaintiff's response is March 29, 2017.

         This motion is based on this Motion, the Memorandum of Points and Authorities filed herewith, the pleadings and papers filed herein and upon such other matters as may be presented to the Court at the time of the hearing

         MEMORANDUM OF POINTS AND AUTHORITIES

         I.

         FACTS

         As the Court is aware, this case is one of thirty-three related lawsuits (“Related Cases”) 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. (See ECF No. 55, 2:4-11).

         On February 27, 2017, Defendant filed their Motion for Summary Judgment. (ECF No. 60). Defendant also filed three other Motions for Summary Judgment in the related cases.[1]

         In Kaplan v. Eldorado Resorts Corporation, et al., the motion consisted of forty-three pages and thirty-eight exhibits (ECF No. 57), a Notice of Filing (ECF No. 58) and Index of Exhibits (ECF No. 58), totaling approximately 460 (four-hundred and sixty) pages. In Barnes v. Eldorado Resorts Corporation, et al., the motion consisted of twenty-eight pages and thirty-five exhibits (ECF No. 60), a Notice of Filing (ECF No. 62) and Index of Exhibits (ECF No. 61), totaling approximately 407 (four-hundred and seven) pages. In Parr v. Eldorado Resorts Corporation, et al., the motion consisted of thirty-one pages and thirty-one exhibits (ECF No. 50), a Notice of Filing (ECF No. 52) and Index of Exhibits (ECF No. 51), totaling approximately 359 (three-hundred and fifty-nine) pages.

         Since February 27, 2017, there's been approximately sixteen depositions that took place with another twelve depositions that were noticed and later continued. Furthermore, the Court held a hearing on March 17, 2017, regarding Defendants' Motions to Disqualify and Motion for Summary Judgment in the Related Cases. On March 23, 2017, Defendant filed an additional five motions for Summary Judgement in the Related Cases.[2]

         The current deadline for Plaintiff to respond to Defendants' dispositive motions is March 29, 2017. (ECF No. 55). Plaintiff files this current motion seeking an additional two weeks of time to provide a meaningful response to Defendants' Motions for Summary Judgment.

         II.

...


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