Dominguez-Hernandez et al v. Las Vegas Metropolitan Police Department et al

Filing 115

ORDER Granting 113 Stipulation re 99 MOTION for Summary Judgment. Replies due by 2/25/2016. IT IS FURTHER ORDERED that 112 Defendants' emergency motion to enlarge/extend time be denied as moot as this Stipulation and Order grants the relief sought. Signed by Judge Andrew P. Gordon on 2/17/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:13-cv-01300-APG-NJK Document 113 Filed 02/16/16 Page 1 of 3

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Marquis Aurbach Coffing
Craig R. Anderson, Esq.
Nevada Bar No. 6882
Tye S. Hanseen, Esq.
Nevada Bar No. 10365
Christian T. Balducci, Esq.
Nevada Bar No. 12688
10001 Park Run Drive
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

MARQUIS AURBACH COFFING

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J.D.H., a minor by and through her legal
guardian and/or parent, Inocente Dominguez; and
MARIA HERNANDEZ, an individual,
Case No.:

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2:13-CV-01300-APG-NJK

Plaintiffs,
VS.
LAS VEGAS METROPOLITAN POLICE
DEPARTMENT; LAS VEGAS
METROPOLITAN POLICE DEPARTMENT
OFFICER J. BARKER (in his individual
capacity); and LAS VEGAS METROPOLITAN
POLICE DEPARTMENT OFFICER M.
PURCARO (in his individual capacity).

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Defendants.

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE
THEIR REPLY IN SUPPORT OF THEIR MOTION FOR SUMMARY JUDGMENT
(First Request)

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Pursuant to LR-6-1, the parties hereby stipulate, agree, and make joint application to
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extend the deadline for Defendants to file their reply in support of their motion for summary
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judgment [Dkt. #99] in this matter as follows:
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Case 2:13-cv-01300-APG-NJK Document 113 Filed 02/16/16 Page 2 of 3

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1.

The Deadline for the Defendants to submit their reply in support of their motion

for summary judgment is presently set for February 18, 2016.
2.

Defendants’ counsel, Mr. Christian Balducci, reached out to Plaintiffs’ counsel on

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February 16, 2016 via email, and not long after sending the email and out of an abundance of

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caution, filed a motion to enlarge/extend time to file the reply in support of the motion for

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summary judgment on an emergency basis. That motion is presently pending as [Dkt. #112]

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(“the Motion”).

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3.

In the Motion, Defendants requested an additional 7 calendar days to file their

reply due to the items raised in the motion and opposition, namely, the busy schedule of Mr.

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Balducci (counsel for Defendants), which includes a trial and arbitration, and the lengths of the

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pleadings.

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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

MARQUIS AURBACH COFFING

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4.

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was filed.

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5.

Defendants’ counsel and Plaintiffs’ counsel were able to speak after the motion

Plaintiffs’ counsel, Ms. Shell, was able to contact Defendants’ counsel later that

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day and respectfully indicated she had no opposition; which would render the motion to enlarge

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time [Dkt. #112] moot and warrant that it be denied as such in light of this stipulation.

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6.

Based upon the foregoing, the parties respectfully request that the Court order:

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a. That the time for Defendants’ reply in support of their motion for

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summary judgment be extended from February 18, 2016 to February 25,

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2016; and

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b. That Defendants’ emergency motion to enlarge/extend time to file reply in

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support of their motion for summary judgment [Dkt. #112] be denied as

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moot upon execution by the Court of this stipulation.

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Case 2:13-cv-01300-APG-NJK Document 113 Filed 02/16/16 Page 3 of 3

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7.

This is the first joint, stipulated request for enlargement of time for Defendants’

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reply and is made in good faith and not for the purpose of delay.

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Dated this 16th day of February, 2016.

Dated this 16th day of February, 2016.

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MARQUIS AURBACH COFFING

MCLETCHIE SHELL, LLC

By: /s/Christian T. Balducci
Craig R. Anderson, Esq.
Nevada Bar No. 6882
Tye S. Hanseen, Esq.
Nevada Bar No. 10365
Christian T. Balducci, Esq.
Nevada Bar No. 12688
10001 Park Run Drive
Las Vegas, Nevada 89145
Attorney for Defendants

By: /s/Alina Shell______________
Margaret A. McLetchie, Esq.
Nevada Bar No. 10931
Alina Shell, Esq.
Nevada Bar No. 11711
701 East Bridger Ave., Suite 520
Las Vegas, Nevada 89101

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GERSON LAW OFFICE
Phillip S. Gerson, Esq.
Nevada Bar No. 5964
1835 Village Center Circle
Las Vegas, NV 89134
Attorneys for Plaintiffs

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10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

MARQUIS AURBACH COFFING

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ORDER
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IT IS ORDERED that Defendants’ reply in support of their motion for summary
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judgment [Dkt. #99] in the above-referenced matter is extended to Thursday February 25,
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2016;
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IT IS FURTHER ORDERED that the Defendants’ emergency motion to enlarge/extend
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time pending as [Dkt. #112] be denied as moot as this Stipulation and Order grants the relief
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sought.
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February 17, 2016

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DATED

UNITED STATES DISTRICT COURT JUDGE

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