Opinion
2:21-cv-01676
01-10-2022
ANGELA WILLIAMS; JANE DOE #1; JANE DOE #2, Plaintiffs, v. STEVE SISOLAK, Governor of Nevada, in his official capacity; AARON FORD, Attorney General of Nevada, in his official capacity; THE CITY OF LAS VEGAS; CLARK COUNTY; NYE COUNTY; WESTERN BEST, INC. D/B/A CHICKEN RANCH; WESTERN BEST LLC; JAMA RASHID; MALLY MALL MUSIC, LLC; FUTURE MUSIC, LLC; PF SOCIAL MEDIA MANAGEMENT, LLC; E.P. SANCTUARY; BLU MAGIC MUSIC, LLC; EXCLUSIVE BEAUTY LOUNGE, LLC; FIRST INVESTMENT PROPERTY, LLC; VIP. ENTERTAINMENT, LLC; MPS PRODUCTIONS, INC.; MMM PRODUCTIONS, INC.; SHAC, LLC D/B/A SAPPHIRE GENTLEMAN'S CLUB AND/OR SAPPHIRE; SHAC MT, LLC; and LAS VEGAS BISTRO, LLC D/B/A LARRY FLYNT'S HUSTLER CLUB, Defendants.
FOX ROTHSCHILD LLP Deanna L. Forbush Rex D. Garner John M. Orr Attorneys for Defendants Western Best, LLC and Western Best Inc. d/b/a Chicken Ranch HUTCHINSON & STEFFEN, PLLC Jason D. Guinasso, Esq. Attorney for Plaintiffs
FOX ROTHSCHILD LLP Deanna L. Forbush Rex D. Garner John M. Orr Attorneys for Defendants Western Best, LLC and Western Best Inc. d/b/a Chicken Ranch
HUTCHINSON & STEFFEN, PLLC Jason D. Guinasso, Esq. Attorney for Plaintiffs
STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO ANSWER DEFENDANT'S MOTION TO DISMISS [DOCKET #98] AND WESTERN DEFENDANT'S PRESERVATION OF RIGHT TO OPPOSE PLAINTIFFS' MOTIONS FOR PROTECTIVE ORDERS [DOCKET #2 AND DOCKET #50] [FIRST REQUEST]
COMES NOW Plaintiffs, Angela Williams, Jane Doe #1, and Jane Doe #2, by and through their counsel of record, HUTCHISON & STEFFEN, PLLC, and Defendants, Western Best, Inc d/b/a Chicken Ranch and Western Best, LLC ("Defendants"), by and through their counsel of record, the law firm of FOX ROTHSCHILD LLP, hereby stipulate and agree to the following regarding Defendants' Motion to Dismiss filed on December 23, 2021 [Docket #98]:
1. This is the first stipulation for extension of time to file a response to Defendants' Motion to Dismiss [Docket #98];
2. Plaintiffs Angela Williams, Jane Doe #1, and Jane Doe #2 have a two-week extension to file and opposition to Defendants' Motion to Dismiss [Docket # 98], extending their deadline to respond to January 20, 2022; and
3. The reason for the extension is Pursuant to Local Rules, Plaintiffs Angela Williams, Jane Doe #1, and Jane Doe #2 have "fourteen days after service of the response" to file their reply. See LR 7-2(b). Fourteen days after the service of the response is Thursday, January 6, 2022. Counsel for Plaintiffs Angela Williams, Jane Doe #1, and Jane Doe #2 took an extended holiday from December 24, 2021, until January 4, 2022, to visit friends and family out of state in conjunction with the Christmas and New Year's holidays. Additionally, now legal counsel for Plaintiffs has not contracted COVID. Accordingly, it is agreed that the above extension is agreed upon with good cause.
4. Defendants preserve the right to respond to Plaintiffs' Motions for Protective Orders [Docket #2 and Docket #50], but will not be required to do so until the Court rules on all the currently pending dispositive motions. Plaintiffs will not seek a ruling on their respective Motions for Protective Orders until Defendants are permitted a reasonable period of time to oppose the same. IT IS SO STIPULATED.
ORDER
IT IS HEREBY ORDERED that Plaintiffs, Angela Williams; Jane Doe #1; and Jane Doe #2 have an extension of time for Plaintiffs to file their Response to Defendants' Motion to Dismiss [Docket # 98] to January 20. 2022.
IT IS SO ORDERED.