Jazlene Baez, Individually and on Behalf of All Others Similarly Situated v. L Ibra, LLC

• Court: District Court, D. Nevada
• Decided: February 25, 2026
• Docket: 2:24-cv-02096
• Status: Unknown

Opinion

1 NICHOLAS M. WIECZOREK, ESQ. Nevada Bar No. 6170 2 CAMI M. PERKINS, ESQ. Nevada Bar No. 9149 3 CLARK HILL PLLC 4 1700 South Pavilion Center Drive, Suite 500 Las Vegas, Nevada 89135 5 Telephone:(702) 697-7545 Facsimile: (702)862-8400 6 nwieczorek@clarkhill.com cmperkins@clarkhill.com 7 Attorneys for Defendant 8 L IBRA, LLC 9 UNITED STATES DISTRICT COURT 10 FOR THE DISTRICT OF NEVADA 11 12 Case No.: 2:24-cv-02096-JAD-EJY JAZLENE BAEZ, Individually and on Behalf of 13 All Others Similarly Situated, STIPULATION AND ORDER TO EXTEND 14 Plaintiffs, PROPOSED JOINT PRETRIAL ORDER DEADLINE 15 v. (FIRST REQUEST) 16 LIBRA, LLC, 17 Defendant. 18 19 Defendant Libra, LLC (“Libra”), by and through its counsel Nicholas M. Wieczorek, Esq., 20 Cami M. Perkins, Esq., of the law firm Clark Hill PLLC, hereby stipulate to extend the pre-trial order 21 deadline for a period of sixty (60) days. 22 Counsel for plaintiff and defendant have been in settlement discussions for approximately three 23 weeks. Ongoing settlement discussions may lead to the resolution of this case. Further, the parties 24 stipulated for additional discovery and fact finding which needs to be completed within the extended 25 compliance period. Final discovery in this matter was delayed due to defense counsel’s recent 26 substitution into the case in late December, 2025, which resulted in minimal delays occasioned by the 27 transition of defense counsel. The parties intend to continue to negotiate in good faith during the 28 extended time period before filing the pretrial order with a goal of reaching settlement of the case. 1 District courts have inherent power to control their dockets, including any requests by the 2 parties to continue an existing trial setting (Hamilton Copper & Steel Corp., v. Primary Steel, Inc., 3 898 F.2d 1428, 1429 (9th Cir. 1990); Oliva v. Sullivan, 958 F.2d 272, 273 9th Cir. 1992)). A motion 4 for continuance of trial should be granted for good cause (Fed.R.Civ.P. 16(b)(4). The trial court has 5 discretion as to what constitutes good cause (See U.S. v. Makley, 468 F.2d 916, 917 (9th Cir. 1972)). 6 The good-cause standard is met where a deadline cannot be met despite the moving party’s 7 diligence (Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)). In 8 determining whether to grant a continuance of a trial date, the Court considers four factors: (1) the 9 movant’s diligence in preparing for the date set for trial; (2) the likelihood that a continuance will 10 address the need giving rise to the motion for a continuance; (3) the extent to which a continuance 11 will inconvenience the court and the opposing party, including its witnesses; and (4) whether the 12 movant will suffer prejudice if the continuance is denied (United States v. Flynt, 756 F.2d 1352, 13 1358 (9th Cir.), amended, 764 14 / / 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 F.2d 675 (9th Cir. 1985)). The weight attributed to any single factor may vary with the extent of the 2 showings on the other factors. 3 The parties anticipate being able to conclude all settlement negotiations, factual investigation 4 and other efforts to achieve case resolution within the extended time period. 5 WHEREFORE, the parties stipulate the deadline for filing the pretrial order be extended up to 6 and including April 27, 2026 7 SO STIPULATED. 8 DATED this 23rd day of February 2026. DATED this 23rd day of February 2026. 9 CLARK HILL PLLC DE CASTROVERDE LAW GROUP 10 11 /s/ Nicholas M. Wieczorek /s/ Ryan Samano NICHOLAS M. WIECZOREK, ESQ. ALEX J. DE CASTROVERDE, ESQ. 12 Nevada Bar No. 6170 Nevada Bar No. 6950 CAMI M. PERKINS, ESQ. RYAN SAMANO, ESQ. 13 Nevada Bar No. 9149 Nevada Bar No. 15995 14 1700 South Pavilion Center Drive, Suite 500 1149 S. Maryland Pkwy. Las Vegas, Nevada 89135 Las Vegas, NV 89104 15 Attorneys for Defendant Attorneys for Plaintiffs LIBRA, LLC 16

17 18 IT IS SO ORDERED. 19 20 21 22 _________________________________________ UNITED STATES MAGISTRATE JUDGE 23 Date: February 25, 2026 24 25 26 27 28