Opinion
2:23-cv-01659-CDS-EJY
10-24-2023
Isaac Dwek, individually and on behalf of all others similarly situated, Plaintiffs, v. Caesars Entertainment, Inc. and DOES 1 through 10, inclusive, Defendants.
ADAM HOSMER-HENNER (NSBN 12779) CHELSEA LATINO (NSBN 14227) JANE SUSSKIND (NSBN 15099) MCDONALD CARANO LLP LATHAM & WATKINS LLP SERRIN TURNER (PRO HAC VICE TO BE FILED) ATTORNEYS FOR DEFENDANT CAESARS ENTERTAINMENT, INC. [ADDITIONAL COUNSEL ON SIGNATURE PAGE] KIND LAW Michael Kind, Esq. Attorney for Plaintiff Isaac Dwek and on behalf of all others similarly situated LATHAM & WATKINS LLP Serrin Turner (pro hac vice to be filed) Attorneys for Defendant Caesars Entertainment, IncQ
ADAM HOSMER-HENNER (NSBN 12779)
CHELSEA LATINO (NSBN 14227)
JANE SUSSKIND (NSBN 15099)
MCDONALD CARANO LLP
LATHAM & WATKINS LLP
SERRIN TURNER (PRO HAC VICE TO BE FILED)
ATTORNEYS FOR DEFENDANT CAESARS ENTERTAINMENT, INC. [ADDITIONAL COUNSEL ON SIGNATURE PAGE]
KIND LAW Michael Kind, Esq. Attorney for Plaintiff Isaac Dwek and on behalf of all others similarly situated
LATHAM & WATKINS LLP Serrin Turner (pro hac vice to be filed) Attorneys for Defendant Caesars Entertainment, IncQ
STIPULATION AND [PROPOSED] ORDER CONTINUING TIME FOR DEFENDANT CAESARS ENTERTAINMENT, INC. TO RESPOND TO COMPLAINT
(FIRST REQUEST)
Defendant Caesars Entertainment, Inc. (“Caesars”) and Plaintiff Isaac Dwek (“Plaintiff”), by and through their undersigned counsel, hereby stipulate and agree as follows and jointly request that the Court enter an Order approving this Stipulation;
WHEREAS, on September 18, 2023, Plaintiffs filed their class action complaint in the Eighth Judicial District Court, Clark County, Nevada, Isaac Dwek v. Caesars Entertainment, Inc., et al. No. A-23-877949-C;
WHEREAS, Caesars was served with the Dwek complaint on September 22, 2023;
WHEREAS, on October 12, 2023, Caesars removed the Dwek complaint to the United States District Court for the District of Nevada;
WHEREAS, pursuant to Federal Rule of Civil Procedure 81(c)(2)(C), the deadline for Caesars to answer or otherwise respond to the Complaint was October 19, 2023.
WHEREAS, seven additional actions arising from the same subject matter as the Dwek complaint are currently pending in this District. The first five of these actions filed in this District have been related, with the lead case being Rodriguez v. Caesars Entertainment, Inc., No. 2:23-cv-01447-ART-BNW (“Related Cases”);
WHEREAS, Plaintiffs in the Related Cases have filed an Unopposed Motion to Consolidate the Related cases, which is currently pending before the Honorable Judge Anne R. Traum;
WHEREAS, Caesars anticipates that the Dwek action will be related to and/or consolidated with the Related Cases, and has filed a Notice of Related Cases in this action (ECF No. 3);
WHEREAS, the parties in the Related Actions have agreed to stay Caesars's deadline to answer or otherwise respond to the complaints pending the filing of a Consolidated Complaint, or a decision denying the Motion to Consolidate;
WHEREAS, to avoid unnecessary expenditure of resources and effort responding to the complaint in this action where all parties are agreed that the Related Actions should be consolidated, and while the Motion to Consolidate is currently pending, the Parties have agreed to extend the time for Caesars to respond to the complaint in this action for forty-five (45) days, until December 4, 2023. ///
There is good cause to grant this request, which is not made for the purposes of delay. The Parties have not previously stipulated to any extensions of time to answer or otherwise respond to the Complaint.
It is therefore STIPULATED and AGREED that:
1. Defendant's deadline to file and serve any answer or other response to the Complaint is extended until December 4, 2023.
IT IS SO ORDERED.