Opinion
2:19-cv-01536-RFB-BNW
04-04-2022
TRUSTEES OF THE NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, PENSION TRUST; TRUSTEES OF THE NEVADA RESORT 'ASSOCIATION INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, WAGE DISABILITY TRUST; and TRUSTEES OF THE NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, APPRENTICE AND JOURNEYMAN TRAINING AND EDUCATION TRUST, Plaintiffs, v. RAMPARTS, LLC dba Luxor Hotel & Casino, a Nevada limited liability company; NEW CASTLE CORP. dba Excalibur Hotel & Casino, a Nevada corporation; and CIRCUS CIRCUS CASINOS INC. d/b/a CIRCUS CIRCUS HOTEL & CASINO, a Nevada corporation, Defendants.
THE URBAN LAW FIRM Michael A. Urban JACKSON LEWIS, P.C. Paul T. Trimmer Lynne K. McChrysta Esq.
THE URBAN LAW FIRM
Michael A. Urban
JACKSON LEWIS, P.C.
Paul T. Trimmer
Lynne K. McChrysta Esq.
STIPULATION AND ORDER
EXTEND DISPOSITIVE MOTIONS DEADLINES
(FIFTH REQUEST)
IT IS HEREBY STIPULATED by and between Plaintiffs, TRUSTEES OF THE NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, PENSION TRUST; TRUSTEES OF THE NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, WAGE DISABILITY TRUST; and TRUSTEES OF THE NEVADA RESORT ASSOCIATION-INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES AND MOVING PICTURE MACHINE OPERATORS OF THE UNITED STATES AND CANADA, LOCAL 720, APPRENTICE AND JOURNEYMAN TRAINING AND EDUCATION TRUST (“Plaintiffs”), through their counsel The Urban Law Firm, and Defendants Ramparts, LLC dba Luxor Hotel & Casino, New Castle Corp. dba Excalibur Hotel & Casino, Circus Circus Casinos Inc. dba Circus Circus Hotel & Resort, (“Defendants”) through their counsel Jackson Lewis P.C., hereby stipulate and request to extend the dispositive motions deadline up to and including June 8, 2022. In support of this Stipulation and Request, the parties state the following:
Defendant New Castle, LLC, is incorrectly named “New Castle Corp.” in the Complaint.
The Complaint incorrectly identifies Circus Circus Casinos, Inc. dba Circus Circus Hotel & Resort as “dba Circus Circus Hotel & Casino.”
1. The current deadline for filing dispositive motions in this case is April 8, 2022. Counsel for the parties propose that a new date for this deadline should be June 8, 2022.
2. Generally, the deadline for the joint pretrial order is 30 days after the dispositive motion deadline. See LR 26-1(b)(5). Thus, the current Joint Pretrial Order deadline in this case is May 9, 2022. Counsel proposes that the new date for this deadline is July 8, 2022. In the event the dispositive motions are pending before the Court on that date, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days after the date of the Court's decision on the last dispositive motion.
3. The parties are continuing to review Plaintiff s audit results and discuss potential resolution of Plaintiff s claims. To that end, the parties are exploring the possibility of retaining the Honorable Peggy Leen (ret.) to mediate their dispute. Based on the dates provided by Judge Leen, the parties anticipate that the latest date they would mediate their dispute would be May 31, 2022. This would render any dispositive motions unnecessary. However, in the event that the dispute is not resolved, the Parties are requesting that the dispositive motions deadline to a date after the last potential mediation date.
4. This request is made in good faith and not for the purpose of delay.
5. Nothing in this Stipulation, nor the fact of entering to the same, shall be construed as waiving any claim and/or defense held by any party.
ORDER
IT IS SO ORDERED: