Howard v. Foster et al
Filing
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ORDER Granting 157 Stipulation to Extend Time re 145 Motion for Reconsideration and Certain Post-Trial Deadlines. See Order for deadlines. Signed by Judge Richard F. Boulware, II on 1/14/2019. (Copies have been distributed pursuant to the NEF - ADR)
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MARGARET A. MCLETCHIE, NV Bar # 10931
ALINA M. SHELL, NV Bar # 11711
MCLETCHIE LAW
701 East Bridger Ave., Suite 520
Las Vegas, Nevada 89101
Telephone: (702) 728-5300
Facsimile: (702) 425-8220
E-mail: maggie@nvlitigation.com
Attorneys for Plaintiff, Reginald Howard
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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,
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
(Third Request)
vs.
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S. FOSTER, et al.,
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Defendants.
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Plaintiff Reginald Howard, by and through his attorneys Margaret A. McLetchie
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and Alina M. Shell, of the law firm McLetchie Law and along with Defendants, Sean
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Bloomfield, Aaron Dicus, and Gustavo Sanchez, by and through counsel, Attorney General
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Adam Paul Laxalt, and Senior Deputy Attorney General Frank A. Toddre II, of the State of
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Nevada, Office of the Attorney General, 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. 156) shall be
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extended from December 21, 2018 to January 22, 2019.
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Second, Defendants have filed a Motion for Reconsideration under Rule 59. (ECF
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No. 145). Plaintiff’s deadline to respond to that Motion shall be extended from January 17,
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2019 to February 18, 2019.
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Third, Defendants have filed a Limited Objection to the Bill of Costs filed by
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Plaintiff on September 20, 2018 (ECF No. 146). Plaintiff’s reply, if any, to any Objection
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shall be extended from December 21, 2018 to January 22, 2019.
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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 parties
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are currently discussing settlement and wish to reduce the accumulation of attorney’s fees.
Moreover, other deadlines have interfered with Plaintiff’s preparation of the
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proposed order, response to the Motion for Reconsideration, and reply to the Objection to
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the Bill of Costs. Specifically, counsel for Plaintiff has an Answering Brief /Opening Brief
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on Cross-Appeal due on December 20, 2018 in City of Henderson v. Las Vegas Review-
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Journal, Nev. S. Ct. Case No. 75407. Additionally, counsel for Plaintiff will be out of the
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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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jurisdiction December 21, 2018 through December 29, 2018.
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IT IS SO STIPULATED.
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DATED this 19th day of December, 2018.
DATED this 19th day of December, 2018.
/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
(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: January 14, 2019.
UNITES STATES DISTRICT COURT JUDGE
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