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)

Download PDF
Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 1 of 4 1 2 3 Paul S. Padda, Esq. (NV Bar #10417) Email: PAUL PADDA LAW, PLLC 4240 West Flamingo Road, Suite 220 Las Vegas, Nevada 89103 Tele: (702)366-1888 4 Fax:(702)366-1940 5 Attorney for the Plaintiff 6 UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF NEVADA 8 9 I SH EN DONNA SOPHIA McLAINE, Plaintiff, 10 ) ) ) ) Case No. 2:14-cv-0288-JAD-GWF 11 v. 12 CLARK COUNTY, NEVADA; et. al. , 13 Defendants. 14 ) ) ) ECF No. 116 ) ) ) ) STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT 15 16 (THIRD REQUEST) 17 Pursuant to Federal Rules of Civil Procedure 6(b) and the Court's Local Rule of 18 19 Civil Practice ("FRCP") 7-1, the parties respectfully request that the Court extend the current 20 deadline for Plaintiff to respond to Defendants' motions for summary judgment (Pacer #109 and 21 #110) to and until May 19.2017 (Friday). This is the parties' third request for an extension of 22 time. Plaintiffs current deadline is April 18, 2017. In support of this stipulation, the parties wish to advise the Court of the following: 23 24 1. This is a civil rights case involving five separate Defendants. Each 25 Defendant moved for summary judgment on January 30, 2017. 26 . . Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 2 of 4 1 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 4 counsel cites the fact that he has been in trial since March 20, 2017 in David Moradi v. Nevada 5 Property 1. LLC, et. ah. Clark County District Court (case number A-14-698824-C). Trial in that 6 matter, a complex case involving a traumatic brain injury, is ongoing and expected to conclude 7 this Friday (April 21,2017) with closing arguments likely to occur on Monday (April 24, 20 1 7). 8 Although undersigned counsel is not the sole attorney representing Plaintiff in the Moradi case, 9 his presence at trial proceedings is necessary and required. 10 3. In the midst of the foregoing, counsel for Plaintiff has also advised that a 11 client of his was just recently indicted on federal charges this past week and is expected before 12 this Court tomorrow for his initial appearance. See United States v. David Nakama Oancea, 13 2: 1 7-cr-01 16-JAD-CWH. The case has generated significant publicity and counsel for Plaintiff 14 was required to unexpectedly de vote significant time this past week to various aspects of the 15 case. 16 4. Counsel for Defendants do not oppose Plaintiffs request for additional 17 time to respond to the dispositive motions provided they are allowed 30-days to file a reply to 18 any response that may be filed by Plaintiff. Obviously, given his own request, Plaintiffs counsel 19 has no issue with providing Defendants additional time to file replies. 20 5. The additional time requested herein should provide sufficient time for 21 Plaintiffs counsel to complete and file an appropriate response. In fact, Plaintiffs counsel is 22 requesting a 30-day extension with the expectation that this will be more than sufficient time to 23 complete responses in this matter despite any unexpected developments that may arise in other 24 cases similar to what has recently occurred. 25 . 26 . 2 Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 3 of 4 1 6. The parties respectfully request that the Court approve this stipulation. 2 Respectfully submitted, /s/ L L. OoxMVUnKy /s/ PcU/U S. Fcui&Oy 4 Lucinda L. Coumou, Esq. 5 Chief Deputy District Attorney, Civil Division Clark County District Attorney's Office 6 Attorney for Defendant Clark County, Nevada 7 Dated: April 18, 2017 Paul S. Padda, Esq. Paul Padda Law Attorney for Plaintiff Dated: April 18, 2017 8 /s/ No~&L E. Bid^vvuyirZy 9 10 Robert W. Freeman, Jr., Esq. Noel E. Eidsmore, Esq. Lewis Brisbois Bisgaard & Smith 11 12 Attorney for Officers Friedman and Zaccara and the Las Vegas Metropolitan Police Department 13 Dated: April 18,2017 14 IT IS SO ORDERED: 15 The Court hereby approves the parties' stipulation for extension of the current deadline for responding to the 16 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 17 18 submit a reply (if any). 19 20 UNITED STATES DISTRICT JUDGE 21 Dated: April 22 23 24 25 26 3 19 , 2017 Case 2:14-cv-00288-JAD-GWF Document 116 Filed 04/18/17 Page 4 of 4 1 CERTIFICATE OF SERVICE 2 3 4 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. 5 /s/ PoaAs S. PaA-do; 6 Paul S. Padda, Esq. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 4

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?