Howard v. Foster et al

Filing 136

ORDER Granting 135 Stipulation for Extension of Time to Submit Proposed Findings of Fact (First Request). Signed by Judge Richard F. Boulware, II on 6/21/2018. (Copies have been distributed pursuant to the NEF - MR)

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Margaret A. McLetchie, Nevada Bar No. 10931
Alina M. Shell, Nevada Bar No. 11711
MCLETCHIE SHELL LLC
701 East Bridger Ave., Suite 520
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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REGINALD HOWARD,

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Plaintiff,

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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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v.

Case No.: 2:13-cv-01368-RFB-NJK
STIPULATION FOR AN EXTENSION
OF TIME TO SUBMIT PROPOSED
FINDINGS OF FACTS
(First Request)

S. FOSTER, et al.,
Defendants.

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COME NOW, Plaintiff, Reginald Howard, by and through his attorneys, Margaret A.

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McLetchie and Alina M. Shell, of the law firm of McLetchie Shell, LLC, along with

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Defendants, Aaron Dicus, Sean Bloomfield, and Gustavo Sanchez, by and through their

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attorneys, Adam Paul Laxalt and Frank A. Toddre II, of Nevada Attorney General’s Office,

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and hereby agree and stipulate to an extension of three weeks to submit simultaneous

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proposed findings of fact as identified at the hearing and to provide a WORD doc version to

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the courtroom deputy. (see Minute Order, ECF No. 134). The current deadline is June 20,

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2018. A three-week extension would make the new deadline for the proposed findings of fact

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due on July 11, 2018.

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This extension is necessary because counsel for Plaintiff has an opposition to an

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Emergency Motion for a Writ of Prohibition due on June 18, 2018 in Las Vegas Metropolitan

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Police Department v. Eighth Judicial District Court, Nevada Supreme Court Case No.

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76023. Counsel for Plaintiff also has an Opposition to a Motion for Summary Judgment due

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on June 22, 2018 in Walker, et al. v. City of North Las Vegas, et al., U.S. Dist. Ct. Case No.

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2:14-cv-01475-JAD-NJK. Counsel for Plaintiff also has a settlement statement due on June

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22, 2018 in Trost v. Cox, et al., U.S. Dist. Ct. Case No. 3:14-cv-0611-MMD-WGC. Further,

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on June 29, 2018, counsel for Plaintiff will be in Boise, Idaho for a settlement conference in

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the Trost matter. Counsel for Defendants in this matter is also counsel for Defendants in

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Trost and thus has the same deadlines for filing a settlement statement and participating in

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the settlement conference in that case. Finally, counsel for Plaintiff has an Answering Brief

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due on July 6, 2018 in Clark County Office of the Coroner/Medical Examiner v. Las Vegas

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Review-Journal, Nevada Supreme Court Case No. 74604.

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This Stipulation is not sought for any improper purpose or other purpose of delay,

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but in the interest of effectively representing Plaintiff’s interests in this matter.

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IT IS SO STIPULATED.

ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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DATED this 15th day of June, 2018.

DATED this 15th day of June, 2018.

/s/ Alina M. Shell
MARGARET A. MCLETCHIE
Nevada Bar No. 10931
ALINA M. SHELL
Nevada Bar No. 11711
MCLETCHIE SHELL, LLC
701 East Bridger Ave., Suite 520
Las Vegas, NV 89101
[phone]
[e-mail]
Attorneys for Plaintiff Reginald Howard

/s/ Frank A. Toddre, II
ADAM PAUL LAXALT
Nevada Bar No.12426
FRANK A. TODDRE II
Nevada Bar No. 11474
OFFICE OF THE ATTORNEY GENERAL
Bureau of Litigation – Public Safety Division
555 E. Washington Ave., Suite 3900
Las Vegas, NV 89101
[phone]
[e-mail]
Attorneys for Defendants

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ORDER

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IT IS SO ORDERED.

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DATED: June 21, 2018

RICHARD F. BOULWARE, II
UNITES STATES DISTRICT JUDGE

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