United States District Court, D. Nevada
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
RICHARD F. BOULWARE, II United States District Judge
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.
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. 51,
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.
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
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
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
A. LEGAL STANDARD ...