Thomas v. United States of America

Filing 16

ORDER Granting 15 Motion to Extend Time to File Dispositive Motions. Motions due by 3/21/2016. Signed by Magistrate Judge Nancy J. Koppe on 1/29/16. (Copies have been distributed pursuant to the NEF - MMM)

1
2
3
4
5
6

DANIEL G. BOGDEN
United States Attorney
District of Nevada
PATRICK A. ROSE
Assistant United States Attorney
Nevada Bar No. 5109
333 Las Vegas Boulevard South, Suite 5000
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: 702-388-6787
Email: [e-mail]

7
Attorneys for the United States.
8
9
10
11

UNITED STATES DISTRICT COURT

12

DISTRICT OF NEVADA

13

GREGORY M. THOMAS,
Plaintiff,

14
15
16
17

v.
UNITED STATES OF AMERICA,
Defendant.

)
)
) Case No: 2:15-cv-00291-APG-NJK
)
)
)
)
)
)
)

18
19

MOTION FOR EXTENSION OF TIME TO FILE DISPOSITIVE MOTIONS
(First Request)

20
21

Pursuant to Rule 6(b)(1) of the Federal Rules of Civil Procedure and Rule 6-1 of this

22

Court’s Local Rules, the United States moves for an extension of thirty days, from February

23

19, 2016 to March 21, 2016, to file dispositive motions. There has not been a previous request

24

for an extension of such deadline, although there was a previous, more general extension of the

25

discovery schedule and pretrial deadlines, see order (ECF No. 13).

26

1

1
2
3

In support of this motion, the United States relies on the Memorandum of Points and
Authorities below.
Respectfully submitted this 28th day of January 2016.

4

DANIEL G. BOGDEN
United States Attorney

5
/s/ Patrick A. Rose
PATRICK A. ROSE
Assistant United States Attorney

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

2

1

MEMORANDUM OF POINTS AND AUTHORITIES

2

Federal Rule of Civil Procedure 6(b)(1) and Local Rule 6-1 allow a party to request

3

additional time to perform an act. In this case, the United States respectfully requests this

4

extension for the reasons set forth below.

5

Undersigned defense counsel is currently preparing for a trial in the matter of Kornberg

6

v. United States of America, 2:12-cv-01961-JAD-PAL. The Kornberg case was reassigned to

7

undersigned defense counsel in connection with the departure of an AUSA at the end of

8

November 2015. Trial dates are scheduled for February 2, 3 and 10, 2016. With the Kornberg

9

trial and other duties, undersigned defense counsel will not have time to prepare dispositive

10
11
12
13
14
15
16
17
18

motions in the instant Thomas case by the current deadline of February 19, 2016.
This motion is brought in good faith and not for purposes of undue delay or unfair
prejudice to Plaintiff.
For the reasons above, the United States respectfully requests an extension of time, from
February 19, 2016 to March 21, 2016, to file dispositive motions.
Respectfully submitted this 28th day of January 2016.
DANIEL G. BOGDEN
United States Attorney
/s/ Patrick A. Rose
PATRICK A. ROSE
Assistant United States Attorney

19
20
21

IT IS SO ORDERED:

22
23
24

UNITED STATES DISTRICT JUDGE
United States Magistrate Judge
UNITED STATES MAGISTRATE JUDGE
January 29, 2016
DATED:

25
26

3

PROOF OF SERVICE

1
2
3

I, Patrick A. Rose, AUSA, certify that the following individuals were served with the
MOTION FOR EXTENSION OF TIME TO FILE DISPOSITIVE MOTIONS on this date
by the below identified method of service:

4

Electronic Case Filing:

5

Brian David Nettles [e-mail]

6

Christian Morris [e-mail]

7

Attorneys for Plaintiff.

8
9
10
11

Dated this 28th day of January 2016.
/s/ Patrick A. Rose
PATRICK A. ROSE
Assistant United States Attorney

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

4