Howard v. Foster et al

Filing 158

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: [phone]
Facsimile: [phone]
E-mail: [e-mail]
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
[phone] (T) / [phone] (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
[phone] (T) / [phone] (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
[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: January 14, 2019.
UNITES STATES DISTRICT COURT JUDGE

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