Opinion
2:20-cv-01939-KJD-DJA
04-14-2023
Joshua Husok, Plaintiff v. STATION CASIS, LLC, a Nevada Limited Liability Company; NP RED ROCK, LLC, d/b/a RED ROCK CASI, RESORT AND SPA, a Nevada Limited Liability Company; ROE Business Organizations I-X; and DOE INDIVIDUALS I-X, Inclusive, Defendants. v.
JAMES P. KEMP, ESQ. VICTORIA L. NEAL, ESQ. KEMP & KEMP Attorneys for Plaintiff JOSHUA 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. VICTORIA L. NEAL, ESQ. KEMP & KEMP Attorneys for Plaintiff JOSHUA 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 [FOURTH 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. Defendants have filed a summary judgment motion. (ECF No. 38). The current deadline for Plaintiff to respond is Monday, April 17, 2023. The new requested date is Monday, April 24, 2023.
This request is made in good faith, is not made to cause delay, is submitted pursuant to LRIA 6-1, LR IA 6-2, and LR 7-1, and is the parties' fourth 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 begun working a very reduced schedule and to the extent possible since November 2022. During that time, Ms. Neal 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.
3. The spine surgery occurred on February 8,2023, with an expected recovery of 4-5 weeks. Ms. Neal anticipated returning between March 15, 2023, and March 20, 2023; however, Ms. Neal experienced, and continues to experience, post-operative complications impeding her ability to return to a full-duty schedule.
4. 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.