United States District Court, D. Nevada
BELLISARIO LAW Bradley Bellisario, Esq., Bar #13452 2945 N.
Martin L King Blvd. North Las Vegas, Nevada 89032 Attorney
JACKSON LEWIS PC. Mahna Pourshaban Deverie J. Christensen,
Bar #6596 Mahna Pourshaban, Bar #13743 3800 Howard Hughes
Parkway, Suite 600 Las Vegas, Nevada 89169 Attorney for
Defendant Southwest Gas Corporation.
STIPULATION AND ORDER TO EXTEND TIME TO FILE
PLAINTIFF'S AMENDED COMPLAINT AND DISPOSITIVE MOTION
DEADLINE (Fifth Request)
J. Christensen, Bar No. 6596
firstname.lastname@example.org Mahna Pourshaban, Bar
No. 13743 email@example.com
to LR 26-4, all parties hereby stipulate to extend the
amended complaint and dispositive motion deadlines in this
action as follows.
November 22, 2016, this Court entered an Order granting the
Proposed Discovery Plan and Scheduling Order submitted by the
parties. ECF No. 14.
current dispositive motion deadline is January 15, 2018.
November 2017 through December 12, 2017 the parties engaged
in meaningful settlement discussions, however, the parties
were unable to resolve the entire matter. The parties
subsequently reached agreement for Plaintiff to voluntarily
withdraw some of her claims.
December 22, 2017, the parties submitted a stipulation and
order to dismiss with prejudice Plaintiff's Second,
Third, Fourth, Eighth, and Ninth Claims. ECF No 29.
Around the December holidays, Plaintiff's counsel,
Bradley Bellisario and his family contracted the influenza
Similarly, during the holidays Lead Defense Counsel, Deverie
Christensen and her family contracted the influenza virus.
the Court may already be aware from news outlets, the flu
season has been particularly bad this year.
parties recognize the stipulation to extend the dispositive
motion deadline was due on December 26, 2017. Due to the
unforeseen illnesses experienced by counsel, the parties are
seeking a brief extension of time to meet upcoming deadlines.
Accordingly, the parties stipulate and agree to extend the
deadline for Plaintiff to file her amended complaint