McLaine v. Clark County, Nevada et al

Filing 115

ORDER Granting 114 Stipulation re 109 and 110 MOTIONS for Summary Judgment . (Responses due by 4/18/2017.) Signed by Judge Jennifer A. Dorsey on 4/4/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:14-cv-00288-JAD-GWF Document 114 Filed 04/03/17 Page 1 of 4

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Paul S. Padda, Esq. (NV Bar #10417)
Email: [e-mail]
PAUL PADDA LAW, PLLC
4240 West Flamingo Road, Suite 220
Las Vegas, Nevada 89 1 03
Tele: [phone]

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Fax:[phone]

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Attorney for the Plaintiff

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UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF NEVADA
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9 1 SHENDONNA SOPHIA McLAINE,
Plaintiff,

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) Case No. 2:14-cv-0288-JAD-GWF

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v.

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CLARK COUNTY, NEVADA; et. al.,
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Defendants.
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STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT

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(SECOND REQUEST)
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Pursuant to Federal Rules of Civil Procedure 6(b) and the Court's Local Rule of

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Civil Practice ("LRCP") 7-1, the parties respectfully request that the Court extend the current

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deadline for Plaintiff to respond to Defendants' motions for summary judgment (Pacer #109 and

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#1 10) to and until April 1 8, 2017 (Tuesday). This is the parties' second request for an extension

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of time. Plaintiffs current deadline is April 3, 2017.

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In support of this stipulation, the parties wish to advise the Court of the following:

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1.

This is a civil rights case involving five separate Defendants. Each

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Defendant moved for summary judgment on January 30, 2017.

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Case 2:14-cv-00288-JAD-GWF Document 114 Filed 04/03/17 Page 2 of 4

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2.

Plaintiffs counsel has requested counsel for Defendants agree to this

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preparing responses to Defendants' dispositive motions. In support of this request. Plaintiffs

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counsel cites the fact that he has been in trial since March 20, 2017 in David Moradi v. Nevada

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Property 1. LLC, et. al.. Clark County District Court (case number A-14-698824-C). Trial in that

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matter is ongoing and expected to last approximately two more weeks. Although undersigned

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counsel is not the sole attorney representing Plaintiff in the Moradi case, his presence at trial

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proceedings is required.

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3.

Counsel for Defendants do not oppose Plaintiffs request for additional time to

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respond to the dispositive motions provided they are allowed 30-days to file a reply to any

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response that may be filed by Plaintiff. Obviously, given his own request, Plaintiffs counsel has

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no issue with providing Defendants additional time to file replies.

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The additional time requested herein should provide sufficient time for Plaintiffs

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counsel to complete and file an appropriate response.

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Case 2:14-cv-00288-JAD-GWF Document 114 Filed 04/03/17 Page 3 of 4

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5.

The parties respectfully request that the Court approve this stipulation.

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Respectfully submitted,

/s/

L. CknMwous

/s/ VoajX S. Payday

Lucinda L. Coumou, Esq.

Chief Deputy District Attorney, Civil Division
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Clark County District Attorney's Office

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Attorney for Defendant Clark County, Nevada

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Paul S. Padda, Esq.
Paul Padda Law

Dated: April 3, 2017

Attorney for Plaintiff
Dated: April 3, 2017

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/s/ NcrcL E. Eid^vwrey
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Robert W. Freeman, Jr., Esq.
Noel E. Eidsmore, Esq.
Lewis Brisbois Bisgaard & Smith

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Attorney for Officers Friedman and Zaccara
and the Las Vegas Metropolitan Police Department

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Dated: April 3, 2017

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IT IS SO ORDERED:

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The Court hereby approves the parties' stipulation for
extension of the current deadline for responding to the

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motions for summary judgment filed on January 30,
2017 (Pacer #109 and #110). Plaintiff's responses shall
be due on or before April 18, 2017 and each Defendant
shall have 30-days after Plaintiff files a response to

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submit a reply (if any).

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UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE
Dated: April 4, 2017,
Dated: April

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,2017