McLaine v. Clark County, Nevada et al
Filing
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ORDER granting 116 stipulation to extend time to respond to 109 and 110 Motions for summary judgment. Responses due by 5/19/2017. Each defendant shall have 30 days after plaintiff files a response to submit a reply, if any. Signed by Judge Jennifer A. Dorsey on 4/19/2017. (Copies have been distributed pursuant to the NEF - DC)
Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 1 of 4
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Paul S. Padda, Esq. (NV Bar #10417)
Email: psp@paulpaddalaw.com
PAUL PADDA LAW, PLLC
4240 West Flamingo Road, Suite 220
Las Vegas, Nevada 89103
Tele: (702)366-1888
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Fax:(702)366-1940
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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 I SH EN DONNA 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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ECF No. 116
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STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT
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(THIRD 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 ("FRCP") 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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#110) to and until May 19.2017 (Friday). This is the parties' third request for an extension of
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time. Plaintiffs current deadline is April 18, 2017.
In support of this stipulation, the parties wish to advise the Court of the following:
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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 116 Filed 04/18/17 Page 2 of 4
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Plaintiffs counsel has requested counsel for Defendants agree to this
2 II stipulation based upon his current trial/work schedule and the need to devote sufficient time to
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. ah. Clark County District Court (case number A-14-698824-C). Trial in that
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matter, a complex case involving a traumatic brain injury, is ongoing and expected to conclude
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this Friday (April 21,2017) with closing arguments likely to occur on Monday (April 24, 20 1 7).
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Although undersigned counsel is not the sole attorney representing Plaintiff in the Moradi case,
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his presence at trial proceedings is necessary and required.
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In the midst of the foregoing, counsel for Plaintiff has also advised that a
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client of his was just recently indicted on federal charges this past week and is expected before
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this Court tomorrow for his initial appearance. See United States v. David Nakama Oancea,
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2: 1 7-cr-01 16-JAD-CWH. The case has generated significant publicity and counsel for Plaintiff
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was required to unexpectedly de vote significant time this past week to various aspects of the
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case.
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4.
Counsel for Defendants do not oppose Plaintiffs request for additional
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time to respond to the dispositive motions provided they are allowed 30-days to file a reply to
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any response that may be filed by Plaintiff. Obviously, given his own request, Plaintiffs counsel
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has no issue with providing Defendants additional time to file replies.
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The additional time requested herein should provide sufficient time for
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Plaintiffs counsel to complete and file an appropriate response. In fact, Plaintiffs counsel is
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requesting a 30-day extension with the expectation that this will be more than sufficient time to
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complete responses in this matter despite any unexpected developments that may arise in other
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cases similar to what has recently occurred.
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.
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.
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Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 3 of 4
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The parties respectfully request that the Court approve this stipulation.
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Respectfully submitted,
/s/ L
L. OoxMVUnKy
/s/ PcU/U S. Fcui&Oy
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Lucinda L. Coumou, Esq.
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Chief Deputy District Attorney, Civil Division
Clark County District Attorney's Office
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Attorney for Defendant Clark County, Nevada
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Dated: April 18, 2017
Paul S. Padda, Esq.
Paul Padda Law
Attorney for Plaintiff
Dated: April 18, 2017
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/s/ No~&L E. Bid^vvuyirZy
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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 18,2017
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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 May 19, 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 DISTRICT JUDGE
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Dated: April
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, 2017
Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 4 of 4
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CERTIFICATE OF SERVICE
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In compliance with the Court's Local Rules, the undersigned hereby certifies that on
April 1 8, 2017 a copy of the foregoing document, "STIPULATION FOR EXTENSION OF
TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTIONS FOR SUMMARY
JUDGMENT" was served (via the Court's CM/ECF system) upon all counsel of record in this
litigation.
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/s/ PoaAs S. PaA-do;
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Paul S. Padda, Esq.
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