McLaine v. Clark County, Nevada et al

Filing 119

ORDER Granting 118 Stipulation for Extension of Time re 109 and 110 MOTIONS for Summary Judgment. (Responses due by 5/23/2017.) Signed by Judge Jennifer A. Dorsey on 5/19/17. (Copies have been distributed pursuant to the NEF - ADR)

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Case 2:14-cv-00288-JAD-GWF Document 118 Filed 05/19/17 Page 1 of 3 1 4 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 Fax:(702)366-1940 5 Attorney for the Plaintiff 2 3 6 UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF NEVADA 8 9 SHENDONNA SOPHIA McLAINE, Plaintiff, 10 ) ) ) ) Case No. 2:14-cv-0288-JAD-GWF 11 I v. 12 CLARK COUNTY, NEVADA; et. aL, 13 Defendants. 14 ) ) ) ) ) STIPULATION FOR EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT 15 16 (FOURTH REQUEST) 17 Pursuant to Federal Rules of Civil Procedure 6(b) and the Court's Local Rule of 18 19 Civil Practice ("LRCP") 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 #1 10) to and until May 23. 2017 (Tuesday). This is the parties' fourth request for an extension of 22 time. Plaintiffs current deadline is May 19, 2017. 23 In support of this stipulation, the parties wish to advise the Court of the following: 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 118 Filed 05/19/17 Page 2 of 3 2. 1 Plaintiffs counsel recently completed a 7-week jury trial in state court that 2 required a significant amount of his time and detracted from his ability to complete responses to 3 the pending motions for summary judgment. While Plaintiffs counsel has commenced drafting 4 responses and made significant progress towards their completion, an additional 2-business days 5 will permit him to complete and file appropriate responses. To this end, undersigned counsel 6 will work over the weekend to ensure their completion and avoid any further extensions of time. 3. 7 Counsel for Defendants do not oppose Plaintiffs request for additional 8 time to respond to the dispositive motions provided they are allowed 30-days to file a reply to 9 any response that may be filed by Plaintiff. Obviously, given his own request, Plaintiffs counsel 10 has no issue with providing Defendants additional time to file replies. 11 12 4. The additional time requested herein should provide sufficient time for Plaintiffs counsel to complete and file appropriate responses. 13 5. The parties respectfully request that the Court approve this stipulation. 14 Respectfully submitted, 15 /s/ 16 Lucinda L. Coumou, Esq. Chief Deputy District Attorney, Civil Division Clark County District Attorney's Office 17 L. Cov^m^n/y /s/ PcuaT S. Fcuido-< Paul S. Padda, Esq. Paul Padda Law Attorney for Plaintiff 18 Attorney for Defendant Clark County, Nevada 19 Dated: May 19, 2017 Dated: May 19, 2017 20 /s/ NcrtL E. EiA^wuyrt21 Robert W. Freeman, Jr., Esq. 22 Noel E. Eidsmore, Esq. Lewis Brisbois Bisgaard & Smith 23 24 Attorney for Officers Friedman and Zaccara and the Las Vegas Metropolitan Police Department 25 Dated: May 19,2017 26 2 Case 2:14-cv-00288-JAD-GWF Document 118 Filed 05/19/17 Page 3 of 3 1 IT IS SO ORDERED: 2 The Court hereby approves the parties' stipulation for extension of the current deadline for responding to the motions for summary judgment filed on January 30, 2017 (Pacer #109 and #110). Plaintiffs responses shall be due on or before May 23, 2017 and each Defendant shall have 30-days after Plaintiff files a response to submit a reply (if any). 3 4 5 6 7 UNITED STATES DISTRICT JUDGE 8 Dated: May 19 2017 9 CERTIFICATE OF SERVICE 10 11 12 In compliance with the Court's Local Rules, the undersigned hereby certifies that on May 19, 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. 13 /s/ Vcu/Ay S. Pa^Ldos 14 Paul S. Padda, Esq. 15 16 17 18 19 20 21 22 23 24 25 26 3

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