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Lockett v. Pinnacle Entertainment Inc.

United States District Court, D. Nevada

April 16, 2019

KRYSTAL LOCKETT, et al., individually, and on behalf of all others similarly situated, Plaintiffs,
v.
PINNACLE ENTERTAINMENT, INC., et al., Defendants.

          JENNY L. FOLEY, Ph.D., ESQ. Nevada Bar No. 9017, MARTA D. KURSHUMOVA, ESQ. Nevada Bar No. 14728, HKM EMPLOYMENT ATTORNEYS LLP, STUEVE SIEGEL HANSON LLP GEORGE A. HANSON, ESQ, pro hac vice ALEXANDER T. RICKE, ESQ., pro hac vice Counsel for Plaintiffs AND ADDITIONAL COUNSEL LISTED ON SIGNATURE PAGE

          McCLELLAND LAW FIRM, P.C.Ryan L. McClelland RYAN L. MCCLELLAND, ESQ., pro hac vice

          OSMAN & SMAY LLP Matthew E. Osman MATTHEW E. OSMAN, ESQ, KATHRYN S. RICKLEY, ESQ., pro hac vice Counsel for Plaintiffs

          PLAINTIFFS' UNOPPOSED MOTION [AND PROPOSED ORDER] FOR AN EXTENSION OF TIME TO RESPOND TO FOREIGN SUBSIDIARY DEFENDANTS' MOTION TO DISMISS PURSUANT TO RULE 12(b)(2) (ECF No. 30), DEFENDANTS' MOTION TO TRANSFER (ECF No. 31), AND DEFENDANTS' MOTION TO DISMISS PURSUANT TO RULE 12(b)(6) (ECF No. 32)

          ANDREW P. GORDON, UNITED STATES DISTRICT JUDGE

         Pursuant to Federal Rule of Civil Procedure 6(b) and Local Rule IA 6-1, Plaintiffs move the Court for a seven day extension of time - from the current deadline of April 17, 2019, until up to and including April 24, 2019 - to respond to Defendants' three pending motions: (1) the Foreign Subsidiary Defendants' Motion to Dismiss Pursuant to Rule 12(b)(2) (ECF No. 30); (2) Defendants' Motion to Transfer Case to the United States District Court for the Western District of Missouri (ECF No. 31); and (3) Defendants' Motion to Dismiss Pursuant to Rule 12(b)(6) (ECF No. 32).

         In support of this unopposed Motion, Plaintiffs state as follows:

         1. Plaintiffs filed their Class and Collective Action Complaint and Jury Demand on February 21, 2019. (ECF No. 1).

         2. This Court granted Defendants' unopposed request for an extension of time (approximately 19 days) to respond to Plaintiffs' Complaint. (ECF No. 27).

         3. On April 3, 2019, Defendants filed three motions: (1) the Foreign Subsidiary Defendants' Motion to Dismiss Pursuant to Rule 12(b)(2) (ECF No. 30); (2) Defendants' Motion to Transfer Case to the United States District Court for the Western District of Missouri (ECF No. 31); and (3) Defendants' Motion to Dismiss Pursuant to Rule 12(b)(6) (ECF No. 32).

         4. The current deadline for Plaintiffs to respond to Defendants' three pending motions is April 17, 2019.

         5. Plaintiffs are requesting a seven day extension of time, up to and including April 24, 2019, to respond to Defendants' three pending motions. This is Plaintiffs' first request for an extension of time.

         6. Despite the exercise of diligence, counsel for Plaintiffs reasonably believe they will require an additional 7 days (to April 24, 2019) to adequately prepare their responses to Defendants' motions, which cite numerous cases and attach a substantial volume of evidentiary materials. This extension of time is sought for good cause and to ensure that Plaintiffs can fully and fairly present their arguments. This requested extension of time will not prejudice Defendants, nor will it unduly delay the timely disposition of this matter.

         7. This extension of time is also in the interest of justice because it will allow the parties additional time to discuss a written proposal made by Plaintiffs to Defendants on April 9, 2019, that may moot at least some of the issues raised in Defendants' pending motions. Lead counsel for Defendants indicated that she had limited availability to review and discuss that proposal with her clients last week. Plaintiffs are currently awaiting Defendants' response to Plaintiffs' proposal. Lead counsel for Plaintiffs is traveling this week and has limited availability due to an initial case management conference and related meetings occurring in Florida in connection with a new MDL matter.

         8. Defendants' counsel has confirmed that Defendants do not oppose ...


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