United States District Court, D. Nevada
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
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.
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
OF POINTS AND AUTHORITIES
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,
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
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.
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
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.