McLaine v. Clark County, Nevada et al

Filing 117

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: [e-mail]
PAUL PADDA LAW, PLLC
4240 West Flamingo Road, Suite 220
Las Vegas, Nevada 89103
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 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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.

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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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2.

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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3.

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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5.

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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6.

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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