Opinion
2:19-cv-00624-RFB-VCF
10-18-2023
HAYRI OLIVAS-ARENAS, individually, Plaintiff, v. HOBBY LOBBY STORES, INC. d/b/a HOBBY LOBBY #679 d/b/a HOBBY LOBBY; 2199 NORTH RAINBOW BOULEVARD HOLDINGS, LLC; DOES 1 through 100 and ROE CORPORATIONS 1 through 100, inclusive, Defendants.
FARHAN R. NAQVI Nevada Bar No. 8589 PAUL G. ALBRIGHT Nevada Bar No. 14159 NAQVI INJURY LAW Attorneys for Plaintiff MICHAEL P. LOWRY Nevada Bar No. 10666 Attorney for Defendants
FARHAN R. NAQVI
Nevada Bar No. 8589
PAUL G. ALBRIGHT
Nevada Bar No. 14159
NAQVI INJURY LAW
Attorneys for Plaintiff
MICHAEL P. LOWRY
Nevada Bar No. 10666
Attorney for Defendants
STIPULATION AND ORDER TO EXTEND PLAINTIFF'S DEADLINE FOR FILING RESPONSES TO DEFENDANTS' MOTIONS IN LIMINE (SECOND REQUEST)
RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE
Plaintiff HAYRI OLIVAS-ARENAS, by and through her attorneys of record, FARHAN R. NAQVI and PAUL G. ALBRIGHT of NAQVI INJURY LAW, and Defendant HOBBY LOBBY STORES, INC. d/b/a HOBBY LOBBY #679 d/b/a HOBBY LOBBY (“Defendants”), by and through its attorney of record, MICHAEL P. LOWRY of WILSON, ELSER, MOSCOWITZ, EDELMAN & DICKER, LLP, hereby stipulate and agree as follows:
IT IS HEREBY STIPULATED AND AGREED that the deadline for Plaintiff to file her responses to all motions in limine recently filed by Defendants be extended to November 30, 2023, including:
1. Hobby Lobby Stores, Inc.'s Motion in Limine 1: Thomas Jennings [Doc. 58];
2. Hobby Lobby Stores, Inc.'s Motion in Limine 2: Causation Testimony from Treating Physicians [Doc. 59];
3. Hobby Lobby Stores, Inc.'s Motion in Limine No. 3: Undisclosed Damages [Doc. 60];
4. Hobby Lobby Stores, Inc.'s Motion in Limine No. 4: Mark James' Felony Conviction [Doc. 61];
5. Hobby Lobby Stores, Inc.'s Motion in Limine No. 5: Speculation as to When Spill was Created [Doc. 62]; and
6. Hobby Lobby Stores, Inc.'s Motion in Limine No. 6: Post Fall Investigation [Doc. 63].
In accordance with L.R. 16-3(a), replies will only be allowed with leave of court.
This stipulation is not brought for purposes of undue delay or any other improper purpose. Several good causes exist for this extension. Firstly, the trial in this matter is currently set for January 29, 2024, thereby rendering December 29, 2024 as the deadline to file motions in limine pursuant to L.R. 16-3(a). Defense counsel filed the foregoing motions six (6) months early out of an abundance of caution, as he is concerned that he will be very busy at the end of the year with other trials. Secondly, Plaintiff's counsel has a firm setting on October 23, 2023 in a district court case. The trial is expected to last at least two (2) weeks. Lastly, Plaintiff's counsel, Paul G. Albright, Esq., has recently inherited many cases from another one of the associates in his firm, Elizabeth E. Coats, Esq., who is out of the office until January 2024 for maternity leave. Plaintiff's counsel will be covering her cases while she is out of the office, further limiting the time and attention required to fully respond to Defendant's pending motions at this time.
Therefore, the parties respectfully request that the deadline for Plaintiff to file her responses to all of Defendant's motions in limine be extended from October 27, 2023 to November 30, 2023, which is still one (1) month prior to the deadline to file motions in limine. This will not cause any delay in the proceedings.
IT IS SO ORDERED.