Opinion
2:23-cv-1480-JAD-VCF
10-26-2023
TONYA OWENS, individually and on behalf of all others similarly situated Plaintiff, v. MGM RESORTS INTERNATIONAL, Defendant.
Nathan R. Ring NV State Bar No. 12078 STRANCH, JENNINGS & GARVEY, PLLC Jeff Ostrow (admitted pro hac vice) KOPELOWITZ OSTROW FERGUSON WEISELBERG GILBERT Attorneys for Plaintiff and the Proposed Class Todd L. Bice NV State Bar No. 4534 PISANELLI BICE PLLC Angela C. Agrusa (CA State Bar No. 131337)* DLA PIPER LLP (US) *Pro hac vice application forthcoming Attorneys for Defendant MGM Resorts International
Nathan R. Ring NV State Bar No. 12078
STRANCH, JENNINGS & GARVEY, PLLC
Jeff Ostrow (admitted pro hac vice)
KOPELOWITZ OSTROW FERGUSON WEISELBERG GILBERT
Attorneys for Plaintiff and the Proposed Class
Todd L. Bice NV State Bar No. 4534
PISANELLI BICE PLLC
Angela C. Agrusa (CA State Bar No. 131337)*
DLA PIPER LLP (US)
*Pro hac vice application forthcoming
Attorneys for Defendant MGM Resorts International
STIPULATION TO EXTEND TIME TO FILE DEFENDANT'S RESPONSE TO COMPLAINT (FIRST REQUEST)
CAM FERENBACH UNITED STATES MAGISTRATE JUDGE
Pursuant to LR IA 6-1, Plaintiff Tonya Owens and Defendant MGM Resorts International (“MGM”) (collectively, the “Parties”) respectfully stipulate MGM's time to respond to the Complaint be extended from the current deadline of October 30, 2023 to and including December 12, 2023.. This is the first stipulation for an extension of time to file MGM's responsive pleading.
Good cause exists to enlarge the time for MGM to respond to the Complaint. Between September 21 and October 20, 2023, nine other related actions were filed against MGM in two other federal courts (the “Related Actions”). See Kirwan v. MGM Resorts Int'l, No. 2:23-cv-01481 (D. Nev.); Zussman v. VICI Properties 1 LLC, et al., No. 2:23-cv-01537 (D. Nev.); Lackey v. MGM Resorts Int'l, No. 2:23-cv-01549 (D. Nev.); Pircio v. MGM Resorts Int'l, No. 2:23-cv-01550 (D. Nev.); Terezo v. MGM Resorts Int'l, No. 2:23-cv-01577 (D. Nev.); Rundell v. MGM Resorts Int'l, No. 2:23-cv-01698 (D. Nev.); Bezak v. MGM Resorts Int'l, No. 2:23-cv-01719 (D. Nev.); Albrigo v. MGM Resorts Int'l, No. 3:23-cv-01797 (S.D. Cal.); Lassoff v. MGM Resorts Int'l, et al., No. 1:23-cv-20419 (D.N.J.).
MGM's counsel was only recently retained and requires additional time to review, investigate, and analyze the allegations in both the Complaint and the Related Actions. Moreover, based on the Parties' current understanding of the claims, there are significant overlaps between this action and the Related Actions. As such, additional time is required to permit time to meet and confer with the various parties to the Related Actions, evaluate the potential consolidation of the cases, and conserve judicial resources.
The Parties' request is made in good faith to enable MGM to complete an investigation into Plaintiff's claims. Moreover, this case is in its infancy, and this request will not prejudice any party.
WHEREAS the Parties respectfully request that MGM shall have until December 12, 2023 to answer, move, or otherwise respond to the Complaint.
IT IS SO ORDERED.