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Newman v. Eldorado Resorts Corp.

United States District Court, D. Nevada

June 24, 2017

PAULA NEWMAN, 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, Paula Newman

          PLAINTIFF'S REQUEST FOR AN EXTENTION TO FILE AN OPPOSITION TO THE MOTION FOR SUMMARY JUDGEMENT. [Plaintiff's Third Request for an Extension to Respond to Dispositive Motions]

          RICHARD F. BOULWARE, II United States District Judge

         COMES NOW, Plaintiff, PAULA NEWMAN, 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 May 31, 2017. The current deadline for Plaintiff's response is June 30, 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. 51, 2:4-1).

         On May 31, 2017, Defendant filed their Motion for Summary Judgment. (ECF No. 55). Defendant also filed three other Motions for Summary Judgment in the related cases.[1]

         In Newman v. Eldorado Resorts Corporation, et al., the motion consisted of thirty-one pages and fifty-three exhibits (ECF No. 55), a Notice of Filing (ECF No. 57) and Index of Exhibits (ECF No. 56), totaling approximately 652 (six-hundred and fifty-two) pages. In Harel v. Eldorado Resorts Corporation, et al., the motion consisted of thirty and twenty-nine exhibits (ECF No. 48), a Notice of Filing (ECF No. 50) and Index of Exhibits (ECF No. 49), totaling approximately 259 (two-hundred and fifty-nine) pages. In Courey v. Eldorado Resorts Corporation, et al., the motion consisted of twenty-six pages and nineteen exhibits (ECF No.47), a Notice of Filing (ECF No. 49) and Index of Exhibits (ECF No. 48), totaling approximately 211 (two-hundred and eleven) pages. In Santovito. Eldorado Resorts Corporation, et al., the motion consisted of thirty and twenty-eight exhibits (ECF No. 61), a Notice of Filing (ECF No. 63) and Index of Exhibits (ECF No. 62), totaling approximately 489 (Four-hundred and eighty-nine) pages.

         On May 15, 2017, Watkins & Letofsky lost their associate, Amy Buchanan, due to a string of ongoing medical issues. While Amy Buchanan was kept off the Related Cases as a courtesy to Defense counsel, the firm had to redistribute her case load amongst the two Nevada partners and remaining Nevada associate. This caused a delay in the cases the firm is handling.

         The current deadline for Plaintiff to respond to Defendants' dispositive motions is June 30, 2017. Plaintiff files this current motion seeking an extension until July 14, 2017 to provide a meaningful response to Defendants' Motions for Summary Judgment.

         II.

         ARGUMENT A. LEGAL STANDARD ...


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