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)

Case 2:14-cv-00288-JAD-GWF Document 118 Filed 05/19/17 Page 1 of 3

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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]
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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SHENDONNA SOPHIA McLAINE,
Plaintiff,

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)

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

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I

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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(FOURTH 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 May 23. 2017 (Tuesday). This is the parties' fourth request for an extension of

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time. Plaintiffs current deadline is May 19, 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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.

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Case 2:14-cv-00288-JAD-GWF Document 118 Filed 05/19/17 Page 2 of 3

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Plaintiffs counsel recently completed a 7-week jury trial in state court that

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required a significant amount of his time and detracted from his ability to complete responses to

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the pending motions for summary judgment. While Plaintiffs counsel has commenced drafting

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responses and made significant progress towards their completion, an additional 2-business days

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will permit him to complete and file appropriate responses. To this end, undersigned counsel

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will work over the weekend to ensure their completion and avoid any further extensions of time.

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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

Plaintiffs counsel to complete and file appropriate responses.

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The parties respectfully request that the Court approve this stipulation.

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Respectfully submitted,

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/s/

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Lucinda L. Coumou, Esq.
Chief Deputy District Attorney, Civil Division
Clark County District Attorney's Office

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L. Cov^m^n/y

/s/ PcuaT S. Fcuido-<
Paul S. Padda, Esq.
Paul Padda Law
Attorney for Plaintiff

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Attorney for Defendant Clark County, Nevada

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Dated: May 19, 2017

Dated: May 19, 2017

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/s/ NcrtL E. EiA^wuyrt21

Robert W. Freeman, Jr., Esq.
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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: May 19,2017

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Case 2:14-cv-00288-JAD-GWF Document 118 Filed 05/19/17 Page 3 of 3

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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
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).

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UNITED STATES DISTRICT JUDGE

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Dated: May

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2017

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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 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.

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/s/ Vcu/Ay S. Pa^Ldos

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Paul S. Padda, Esq.

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