Perez et al v. Cox et al

Filing 169

ORDER Granting 168 Stipulation for Extension of Time (Second Request) re 153 Motion for Summary Judgment, 147 Motion for Summary Judgment, 146 Motion for Summary Judgment, 159 Motion for Summary Judgment. Responses due by 1/5/2022. Replies due by 2/4/2022. Signed by Judge Andrew P. Gordon on 12/14/2021. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:15-cv-01572-APG-DJA Document 169 Filed 12/14/21 Page 1 of 3

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CLARK HILL PLLC
PAOLA M. ARMENI
Nevada Bar No. 8357
Email: [e-mail]
3800 Howard Hughes Pkwy., #500
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs, Perez Family

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
VICTOR PEREZ, as Special Administrator of
CASE NO.: 2:15-cv-01572-APG-DJA
the Estate of CARLOS PEREZ, deceased;
VICTOR PEREZ, as the Guardia Ad Litem for
S.E.P., a minor; VICTOR PEREZ, as the Guardia
Ad Litem for A.I.P., a minor,
STIPULATION AND ORDER TO
Plaintiffs,
EXTEND MOTION FOR
vs.
SUMMARY JUDGMENT BRIEFING
DEADLINES
STATE OF NEVADA, ex.rel. NEVADA
(Second Request)
DEPARTMENT OF CORRECTIONS;
DIRECTOR GREG COX, individually;
WARDEN DWIGHT NEVEN, individually;
ASSISTANT WARDEN TIMOTHY FILSON,
individually; COT. RAMOS, individually;
LIEUTENANT OLIVER, individually;
CORRECTIONS OFFICER CASTRO,
individually; CORRECTIONS OFFICER
SMITH, individually; and DOES I-X, inclusive;
and ROES I-X, inclusive,
Defendants.
Victor Perez, as Special Administrator of the Estate of Carlos Perez, deceased, by and
through his counsel, Paola M. Armeni, Esq., of the law firm of Clark Hill, Defendant Raynaldo
Ramos, by and through his counsel, Robert W. Freeman, Jr. Esq., of the law firm of Lewis Brisbois
Bisgaard & Smith, LLP, Defendants, State of Nevada ex rel Nevada Department of Corrections,
James Greg Cox, Timothy Filson, Dwight W. Neven and Ronald Oliver, by and through their
counsel, Akke Levin, Esq., of the Attorney General’s Office, Defendant Isaiah Smith, by and
through his counsel of record Jeffrey F. Barr, Esq. of the law firm of Armstrong Teasdale, and
Defendant Jeff Castro, by and through his counsel, James A. Beckstrom, Esq., of the law firm of
Marquis Aurbach Coffing, hereby respectfully submit this Stipulation and Order Extending Time
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Case 2:15-cv-01572-APG-DJA Document 169 Filed 12/14/21 Page 2 of 3

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for: (1) Plaintiff to Respond to Defendant Corrections Officer Castro’s Motion for Summary

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Judgment [Dkt 146], Defendant Raynaldo-John Ramos’ Motion for Summary Judgment [Dkt

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147], State of Nevada Ex Rel. Nevada Department of Corrections, James “Greg” Cox, Timothy

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Filson, Dwight Neven and Ronald Oliver’s Motion for Summary Judgment [Dkt 153], and

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Defendant Isaiah Smith’s Motion for Summary Judgment [Dkt 159] all filed on October 25, 2021,

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which responses are currently due on December 22, 2021, to be extended up to and including

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January 5, 2022; and (2) all Defendants to file their Replies, currently due on January 21, 2021, to

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be extended to and including February 4, 2022.

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The law firm of Plaintiff’s counsel has experienced some unexpected personnel changes.

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Those personnel changes directly affect the work being done on the Plaintiff’s case. As such,

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Plaintiff’s counsel requested a two week extension to file the four Responses to the Defendants’

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Motions for Summary Judgment. Counsel for the Defendants have no objection to extending the

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deadline for Responses and the parties further stipulate to extend the date to reply to Plaintiffs’

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Responses. This request for extension is made in good faith and not for the purposes of delay.

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WHEREFORE, the parties stipulate that the time for Plaintiffs to file their Response(s) to

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Defendant Corrections Officer Castro’s Motion for Summary Judgment [Dkt 146], Defendant

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Raynaldo-John Ramos’ Motion for Summary Judgment [Dkt 147], State of Nevada Ex Rel.

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Nevada Department of Corrections, James “Greg” Cox, Timothy Filson, Dwight Neven and

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Ronald Oliver’s Motion for Summary Judgment [Dkt 153], and Defendant Isaiah Smith’s Motion

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for Summary Judgment [Dkt 159], be extended for two weeks up to and including January 5,

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2022 and the time for Defendants to file their Replies be extended to and including February 4.

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2022. Respectfully submitted this 13th day of December 2021.

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CLARK HILL, PLLC

MARQUIS AURBACH COFFING

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/s/ Paola M. Armeni, Esq.
____________________________
PAOLA M. ARMENI
Nevada Bar No. 8357
3800 Howard Hughes Pkwy., #500
Las Vegas, Nevada 89169
Attorneys for Plaintiffs, Perez Family

/s/ James A. Beckstrom, Esq.
_______________________________
James A. Beckstrom, Esq.
Nevada Bar No. 14032
10001 Park Run Drive
Las Vegas, NV 89145
Attorneys for Defendant Jeffrey Castro

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ARMSTRONG TEASDALE
OFFICE OF THE ATTORNEY
GENERAL

/s/ Jeffrey F. Barr, Esq.
____________________________
Jeffrey F. Barr, Esq.
Nevada Bar No. 007269
3770 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169
Attorneys for Defendant Isaiah Smith

/s/ Akke Levin, Esq.
____________________________
Steven Shevorski, Esq.
Nevada Bar No. 008256
Akke Levin, Esq.
Nevada Bar No. 009102
100 N Carson St
Carson City, NV 89701
Attorneys for Defendants, State of Nevada,
Dwight W. Neven, James Greg Cox
Ronald Oliver, Timothy Filson

LEWIS BRISBOIS BISGAARD &
SMITH LLP
/s/ Robert W. Freeman, Jr., Esq.
__________________________________
Robert W Freeman, Jr., Esq.
Nevada Bar No. 003062
6385 S. Rainbow Blvd., Ste. 600
Las Vegas, NV 89118
Attorneys for Defendant Raynaldo Ramos

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ORDER

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IT IS SO ORDERED:
December 14, 2021
DATED:______________________

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UNITED STATES DISTRICT COURT JUDGE
CASE NO.: 2:15-cv-01572-APG-DJA

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