Howard v. Foster et al
Filing
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ORDER Granting 147 Stipulation to Extend Certain Post-Trial Deadlines. See Order for deadlines. Signed by Judge Richard F. Boulware, II on 10/8/2018. (Copies have been distributed pursuant to the NEF - ADR)
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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: (702) 728-5300
Facsimile: (702) 425-8220
Email: maggie@nvlitigation.com
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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v.
ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
(702)728-5300 (T) / (702)425-8220 (F)
WWW.NVLITIGATION.COM
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Case No.: 2:13-cv-01368-RFB-NJK
STIPULATION TO EXTEND
CERTAIN POST-TRIAL DEADLINES
PENDING POSSIBLE RESOLUTION
OF MATTER
S. FOSTER, et al.,
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(First Request)
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 extend certain post-trial deadlines.
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First, the deadline for Plaintiff to submit a proposed order with underlying
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documentation as to fees and costs pursuant to 42 U.S.C. § 1988. (ECF No. 142) shall be
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extended from October 5, 2018 to November 19, 2018.
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Second, Defendants have filed a Motion for Relief of Judgment under Rule 59 on
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October 4, 2018.1 Plaintiff’s deadline to respond to that Motion shall be extended until
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December 18, 2018.
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The 28-day deadline put forth in FRCP 59(b) is not waivable as a jurisdictional time limit.
As such, the Defendants’ filed this motion to preserve their right to relief while parties were
engaged in post-trial discussion for resolution.
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Third, Defendants have filed an Objection to the Bill of Costs filed by Plaintiff on
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October 4. 2018. Plaintiff’s reply, if any, to any Objection shall be due on November 13,
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2018.
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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. The parties
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are currently discussing settlement and wish to reduce the accumulation of attorney’s fees.
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IT IS SO STIPULATED.
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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
(702)728-5300 (T) / (702)425-8220 (F)
WWW.NVLITIGATION.COM
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DATED this 4th day of October, 2018.
DATED this 4th day of October, 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
(702) 728-5300
maggie@nvlitigation.com
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
(702) 486-3149
ftoddre@ag.nv.gov
Attorneys for Defendants
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ORDER
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IT IS SO ORDERED.
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DATED: October 8, 2018.
__________________________
RICHARD F. BOULWARE, II
UNITES United States District Court
STATES DISTRICT COURT JUDGE
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