Opinion
2:20-cv-01939-KJD-DJA
02-02-2023
JAMES P. KEMP, ESQ., NV Bar #6375 VICTORIA L. NEAL, ESQ., NV Bar 13382 KEMP & KEMP Attorneys for Plaintiff Josh Husok SCOTT M. MAHONEY, ESQ., NV Bar #1099 FISHER & PHILLIPS, LLP Attorneys for Defendants Station Casinos, LLC and NP Red Rock Casino LLC, d/b/a Red Rock Casino Resort and Spa
JAMES P. KEMP, ESQ., NV Bar #6375
VICTORIA L. NEAL, ESQ., NV Bar 13382
KEMP & KEMP
Attorneys for Plaintiff Josh Husok
SCOTT M. MAHONEY, ESQ., NV Bar #1099
FISHER & PHILLIPS, LLP
Attorneys for Defendants Station Casinos, LLC and NP Red Rock Casino LLC, d/b/a Red Rock Casino Resort and Spa
STIPULATION AND ORDER TO EXTEND SUMMARY JUDGMENT BRIEFING SCHEDULE [THIRD REQUEST]
KENT J. DAWSON, UNITED STATES DISTRICT COURT JUDGE.
Plaintiff JOSHUA HUSOK and Defendant STATION CASINOS, LLC and NP RED ROCK, LLC, d/b/a RED ROCK CASINO, RESORT AND SPA, by and through their undersigned counsel, hereby submit this Stipulation and Order to Extend Summary Judgment Briefing Schedule. Defendant have filed a summary judgment motion. (ECF No. 38). The current deadline for Plaintiff to respond is February 20, 2023. The new requested date is Monday, April 17, 2023. This request is made in good faith, is not made to cause delay, is submitted pursuant to LR IA 6-1, LR IA 6-2, and LR 7-1, and is the parties' first request. As demonstrated below, good cause exists for the parties' request:
1. The need for the extension arises from the sudden and unexpected disability of Plaintiff's attorney Victoria L. Neal, Esq. which began in August 2022. The parties have kept the Court informed of her progress and that she has been working a very reduced schedule and to the extent possible since November 2022. During that time, Ms. Neal has responded to motions for summary judgment, filed and responded to several discovery motions, provided responses to discovery requests, and addressed administrative agency matters.
2. In addition to testing, treatment, and therapy, Ms. Neal had a medical procedure on November 21, 2022, and was out the entire week for recuperative purposes, as well as the holiday. The procedure was partially for treatment purposes, as well as serving as further diagnostic testing. In December 2022, it was determined that the November procedure was unsuccessful, and that spine surgery would be required. The spine surgery is scheduled for February 8, 2023, and recovery is expected to take 4-5 weeks. Ms. Neal anticipates returning between March 15, 2023, and March 20, 2023.
3. In consideration of the above, the parties submit that good cause exists to extend the deadline for Plaintiff to respond to Defendants' motion for summary judgment.
IT IS SO ORDERED.