Howard v. Foster et al

Filing 156

ORDER Granting 155 Stipulation to Extend Certain Post-Trial Deadlines. See Order for deadlines. Signed by Judge Richard F. Boulware, II on 11/26/2018. (Copies have been distributed pursuant to the NEF - ADR)

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ADAM PAUL LAXALT
Attorney General
Frank A. Toddre II (Bar No. 11474)
Senior Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Avenue, Suite 3900
Las Vegas, NV 89101
[phone] (phone)
[phone] (fax)
[e-mail]
Attorneys for Defendants Sean Bloomfield
Aaron Dicus, and Gustavo Sanchez

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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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vs.

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S. FOSTER, et al.,

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CASE NO. 2:13-cv-01368-RFB-NJK
STIPULATION TO EXTEND CERTAIN
POST-TRIAL DEADLINES PENDING
POSSIBLE RESOLUTION OF
MATTER
(Second Request)

Defendants.

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

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counsel, Attorney General Adam Paul Laxalt, and Senior Deputy Attorney General Frank

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A. Toddre II, of the State of Nevada, Office of the Attorney General, along with Plaintiff

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Reginald Howard, by and through his attorneys, Margaret A. McLetchie and Alina M.

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Shell, of the law firm McLetchie Law and hereby agree and stipulate to extend certain post-

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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 November 19, 2018 to December 21, 2018.

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Second, Defendants have filed a Motion for Reconsideration under Rule 59. (ECF No.

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145). Plaintiff’s deadline to respond to that Motion shall be extended from December 18,

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2018 to January 17, 2019.

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Third, Defendants have filed a Limited Objection to the Bill of Costs filed by Plaintiff

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on September 20, 2018 (ECF No. 146). Plaintiff’s reply, if any, to any Objection shall be

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extended from November 13, 2018 until December 21, 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 both parties’ interests in this matter. The

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parties are currently discussing settlement and wish to reduce the accumulation of

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attorney’s fees.

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Counsel has been working further to resolve outstanding appellate matters relating

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to Howard’s Appeal in Ninth Circuit Case No. 18-16969. Lastly, Counsel for Defendants

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will be out of jurisdiction from November 13, 2018 until November 22, 2018, and will not

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have any access to e-mail or State files.

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IT IS SO STIPULATED.

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DATED this 13th day of November, 2018.

DATED this 13th day of November, 2018.

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/s/ Alina M. Shell
MARGARET A. MCLETCHIE
Nevada Bar No. 10931
ALINA M. SHELL
Nevada Bar No. 11711
MCLETCHIE LAW
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
IT IS SO ORDERED.

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DATED: November 26, 2018.

UNITES STATES DISTRICT COURT JUDGE

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