Opinion
2:21-cv-001476-APG-NJK
08-31-2022
MGM GRAND HOTEL, LLC d/b/a MGM GRAND; Plaintiff, v. KEVIN CHANG SHENG LONG, Defendant.
SEMENZA KIRCHER RICKARD LAWRENCE C. HILL & ASSOCIATES Lawrence J. Semenza, III, Esq, Bar No. 7174 Lawrence C. Hill, Esq., Bar No. 11989 Katie L. Cannata, Esq., Bar No. 14848 Sean P. O'Callaghan, Esq., Bar No. 15447 Christopher D. Kircher, Esq., Bar No. 11176 Jarrod L. Rickard, Esq., Bar No. 10203 Attorneys for Plaintiff MGM Grand Hotel, LLC d/b/a MGM Grand
SEMENZA KIRCHER RICKARD
LAWRENCE C. HILL & ASSOCIATES
Lawrence J. Semenza, III, Esq, Bar No. 7174
Lawrence C. Hill, Esq., Bar No. 11989
Katie L. Cannata, Esq., Bar No. 14848
Sean P. O'Callaghan, Esq., Bar No. 15447
Christopher D. Kircher, Esq., Bar No. 11176
Jarrod L. Rickard, Esq., Bar No. 10203
Attorneys for Plaintiff MGM Grand Hotel, LLC d/b/a MGM Grand
STIPULATION AND ORDER TO EXTEND DEADLINE TO ADDRESS PLAINTIFF'S REMAINING CLAIMS (FIRST REQUEST)
Pursuant to LR IA 6-1 and 6-2, Plaintiff MGM Grand Hotel, LLC d/b/a MGM Grand ("Plaintiff"), by and through its counsel, Lawrence J. Semenza, III, Esq. and Katie Cannata, Esq. of the law firm Semenza Kircher Rickard, and Defendant Kevin Chang Sheng Long ("Long"), by and through his counsel, Lawrence C. Hill, Esq. of Lawrence C. Hill & Associates, hereby stipulate and agree to the following:
1. On August 22, 2022, the Court issued an Order Granting in Part Plaintiff's Motion for Summary Judgment and Denying Motion to Strike as Moot. [ECF No. 41.]
2. The Court ordered that by August 29, 2022, Plaintiff shall either (1) dismiss its two remaining claims against Long and prepare a proposed form of judgment reflecting the total amount due as of September 1, 2022, or (2) advise the court how it intends to proceed on its claims for Unjust Enrichment and Breach of the Implied Covenant of Good Faith and Fair Dealing.
3. The Parties require additional time to continue to explore a potential resolution of this case and determine how to proceed with Plaintiff's remaining claims. The Parties believe that an additional two (2) weeks will be sufficient in order for counsel to confer with their respective clients as to the foregoing issues.
4. Accordingly, the Parties hereby request that the current deadline of August 29, 2022 be extended for an additional two (2) weeks, up to and including September 12, 2022.
IT IS SO ORDERED.