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Olshansky v. Eldorado Resorts Corp.

United States District Court, D. Nevada

April 24, 2017

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

          Daniel R. Watkins Nevada State Bar No. 11881 Brian S. Letofsky Nevada State Bar No. 11836 Eran S. Forster Nevada State Bar No. 11124 WATKINS & LETOFSKY, LLP Attorneys for Plaintiff, Steven Olshansky

          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, STEVEN OLSHANSKY, 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 March 23, 2017. The current deadline for Plaintiff's response is April 24, 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. 61, 2:4-1).

         On March 23, 2017, Defendant filed their Motion for Summary Judgment. (ECF No. 68). Defendant also filed three other Motions for Summary Judgment in the related cases.[1]

         In Bouch v. Eldorado Resorts Corporation, et al., the motion consisted of thirty-one pages and thirty-nine exhibits (ECF No. 68), a Notice of Filing (ECF No. 70) and Index of Exhibits (ECF No. 69), totaling approximately 402 (four-hundred and two) pages. In Olshansky v. Eldorado Resorts Corporation, et al., the motion consisted of eighteen pages and twenty exhibits (ECF No. 62), a Notice of Filing (ECF No. 64) and Index of Exhibits (ECF No. 63), totaling approximately 271 (two-hundred and seventy-one) pages. In Parr v. Eldorado Resorts Corporation, et al., the motion consisted of thirty-one pages and twenty-three exhibits (ECF No. 53), a Notice of Filing (ECF No. 55) and Index of Exhibits (ECF No. 54), totaling approximately 261 (two-hundred and sixty one) pages. In Sekkatv. Eldorado Resorts Corporation, et al., the motion consisted of twenty-five and twelve exhibits (ECF No. 64), a Notice of Filing (ECF No. 66) and Index of Exhibits (ECF No. 65), totaling approximately 261 (two-hundred and sixty one) pages.

         Since March 23, 2017, there's been almost daily depositions or cancelled depositions that took place. Furthermore, Plaintiffs' law firm, Watkins & Letofsky, brought back an associate from Medical Leave to help with the instant case and Related Cases. Defense Counsel felt there might be a conflict of interest with the specific associate and she was taken off the case as a courtesy to Defendants. However, a new associate has not yet been hired to replace her tasks on the Related Cases.

         The current deadline for Plaintiff to respond to Defendants' dispositive motions is April 24, 2017. Plaintiff files this current motion seeking an extension until May 15, 2017 to provide a meaningful response to Defendants' Motions for Summary Judgment.

         II.

         ARGUMENT A. LEGAL STANDARD ...


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