Perez et al v. Cox et al

Filing 199

ORDER Granting 198 Stipulation to Extend Response Deadline to 194 Objection. Responses due by 3/18/2022. Signed by Judge Andrew P. Gordon on 3/4/2022. (Copies have been distributed pursuant to the NEF - KF)

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CLARK HILL PLLC
PAOLA M. ARMENI
Nevada Bar No. 8357
Email: [e-mail]
3800 Howard Hughes Pkwy., #500
GIA N. MARINA
Nevada Bar No. 15276
Email: [e-mail]
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs, Perez Family

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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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 DEADLINE FOR PLAINTIFFS’
vs.
TO FILE A RESPONSE TO DEFENDANT
ISAIAH SMITH’S OBJECTION TO
STATE OF NEVADA, ex.rel. NEVADA
PLAINTIFFS’ EVIDENCE IN SUPPORT
DEPARTMENT OF CORRECTIONS;
OF RESPONSE TO MOTION FOR
DIRECTOR GREG COX, individually;
SUMMARY JUDGEMENT [DKT 194]
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,

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Defendants.
Victor Perez, as Special Administrator of the Estate of Carlos Perez, deceased, by and

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through his counsel, Paola M. Armeni, Esq. and Gia N. Marina, Esq., of the law firm of Clark Hill

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and Defendant Isaiah Smith, by and through his counsel of record Jeffrey F. Barr, Esq. of the law

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firm of Armstrong Teasdale, hereby respectfully submit this Stipulation and Order Extending Time

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for Plaintiff to Respond to Defendant Isaiah Smith’s Objections to Plaintiffs’ Evidence in Support

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of Response to Motion for Summary Judgement [Dkt 194] filed on February 18, 2022, which the

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response is currently due on March 4, 2022, to be extended an additional fourteen (14) days up to

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and including March 18, 2022.

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Although Plaintiffs’ counsel has been actively working on responding to Defendant’s

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Objection, counsel requires a brief extension to complete the Response. This request for extension

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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 to

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Defendant Isaiah Smith’s Objections to Plaintiffs’ Evidence in Support of Response to Motion for

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Summary Judgement [Dkt 194], be extended an additional fourteen (14) days up to and including

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March 18, 2022.

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APPROVED AS TO FORM AND CONTENT.

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Respectfully submitted this 3rd day of March 2022.

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CLARK HILL, PLLC

ARMSTRONG TEASDALE

/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/ 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

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ORDER
IT IS SO ORDERED:
March 4, 2022
DATED:______________________

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UNITED STATES DISTRICT COURT JUDGE

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