Howard v. Foster et al

Filing 138

ORDER Granting 137 Stipulation to Extend Time. Proposed Findings of Fact and Conclusions of Law due by 7/25/2018. Signed by Judge Richard F. Boulware, II on 7/11/2018. (Copies have been distributed pursuant to the NEF - ADR)

1
2
3
4
5
6

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

7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9

REGINALD HOWARD,

10

Plaintiff,

11

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

12
13
14

v.

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

S. FOSTER, et al.,
Defendants.

15

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

16

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

17

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

18

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

19

and hereby agree and stipulate to an extension of two weeks to submit simultaneous proposed

20

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

21

courtroom deputy. (See Minute Order, ECF No. 134). The current deadline is July 11, 2018

22

(see Order, ECF No. 136). A two-week extension would make the new deadline for the

23

proposed findings of fact due on July 25, 2018.

24

This extension is necessary because on June 28, 2018, Plaintiff’s counsel

25

determined that she did not have a transcript for Trial Day 4, which occurred on January 8,

26

2018. Plaintiff’s counsel then contacted counsel for Defendants, who indicated he also did

27

not have a transcript for Trial Day 4. That same day, Plaintiff’s counsel sent an email request

28

to the court reporter requesting expedited preparation of the transcript. The court reporter’s

1

1

automated response indicated she was out of the office was out of the office until July 8,

2

2018. Plaintiff’s counsel has since corresponded with the court reporter and order the

3

transcript for Trial Day 4 to be prepared on an expedited basis.

4

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

5

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

6

IT IS SO STIPULATED.

7
8
9
10
11

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

12
13
14
15

DATED this 10th day of July, 2018.

DATED this 10th day of July, 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

16
17

ORDER

18
19

IT IS SO ORDERED.

20
21
22
23

DATED: July 11, 2018

__________________________
RICHARD F. BOULWARE, II
UNITES STATES DISTRICT COURT JUDGE
United States District Court

24
25
26
27
28

2