Perez et al v. Cox et al

Filing 270

ORDER Granting 269 Stipulation to Extend Deadline to File Stipulated Dismissal. Stipulated Dismissal due by 11/28/2023. Signed by Magistrate Judge Daniel J. Albregts on 9/27/2023. (Copies have been distributed pursuant to the NEF - ALZ)

Case 2:15-cv-01572-APG-DJA Document 270 Filed 09/27/23 Page 1 of 3

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CLARK HILL PLLC
PAOLA M. ARMENI
Nevada Bar No. 8357
Email: [e-mail]
GIA N. MARINA
Nevada Bar No. 15276
Email: [e-mail]
1700 S. Pavilion Center Dr., Ste. 500
Las Vegas, Nevada 89135
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs, Perez Family

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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VICTOR PEREZ, as Special Administrator of
the Estate of CARLOS PEREZ, deceased;
VICTOR PEREZ, as the Guardia Ad Litem for
S.E.P., a minor; VICTOR PEREZ, as the
Guardian Ad Litem for A.I.P., a minor,

STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
STIPULATED DISMISSAL
(2nd Request)

Plaintiffs,

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vs.

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STATE OF NEVADA, ex.rel. NEVADA
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,

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CASE NO.: 2:15-cv-01572-APG-DJA

Defendants.
IT IS HEREBY STIPULATED by and between Victor Perez, as Special Administrator of
the Estate of Carlos Perez, deceased, Victor Perez as Guardian Ad Litem for S.E.P. and A.I.P., by
and through his counsel, Paola M. Armeni, Esq., and Gia N. Marina, 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, Kiel Ireland, Esq. of the Attorney General’s Office,
Defendant Isaiah Smith, by and through his counsel of record Jeffrey F. Barr, Esq. and Alina Shell,
Esq. of the law firm of Armstrong Teasdale, and Defendant
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Case 2:15-cv-01572-APG-DJA Document 270 Filed 09/27/23 Page 2 of 3

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Jeff Castro, by and through his counsel, Craig Anderson, Esq., of the law firm of Marquis Aurbach,

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that the deadline to file the Stipulated Dismissal currently September 29, 2023, be continued for

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an additional sixty (60) days, up to and including November 28, 2023.

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The parties request the extension of the deadline for several reasons: (1) the probate court

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is not set to approve the settlement of the estate funds until October 6, 2023; (2) the settlement is

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not set to be approved by the Board of Examiners until October 10, 2023; and (3) distribution of

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the settlement proceeds will not take place until several weeks after approval by the Board. Thus,

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the additional time is needed to ensure the conditions of the settlement are met.

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///

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///

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///

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Case 2:15-cv-01572-APG-DJA Document 270 Filed 09/27/23 Page 3 of 3

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

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APPROVED AS TO FORM AND CONTENT.

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Respectfully submitted this 26th day of September 2023.

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CLARK HILL, PLLC
/s/ Paola M. Armeni, Esq.
PAOLA M. ARMENI
Nevada Bar No. 8357
GIA N. MARINA
Nevada Bar No. 15276
1700 S. Pavilion Center Dr. Ste., #500
Las Vegas, Nevada 89135
Attorneys for Plaintiffs, Perez Family

LEWIS BRISBOIS BISGAARD &
SMITH LLP
/s/ Robert W. Freeman, Jr., Esq.
Robert W Freeman, Jr., Esq.
Nevada Bar No. 3062
6385 S. Rainbow Blvd., Ste. 600
Las Vegas, NV 89118
Attorneys for Defendant Raynaldo Ramos

MARQUIS AURBACH
/s/ Craig R. Anderson, Esq.
Craig R. Anderson, Esq.
Nevada Bar No. 6882
10001 Park Run Drive
Las Vegas, NV 89145
Attorneys for Defendant Jeffrey Castro

OFFICE OF THE ATTORNEY
GENERAL
/s/ Kiel Ireland, Esq.
Kiel Ireland, Esq.
Nevada Bar No. 15368
100 N Carson St
Carson City, NV 89701
Attorneys for Defendants, State of Nevada,
Dwight W. Neven, James Greg Cox
Ronald Oliver, Timothy Filson

ARMSTRONG TEASDALE
/s/ Jeffrey F. Barr, Esq.
Jeffrey F. Barr, Esq.
Nevada Bar No. 7269
Alina Shell, Esq.
Nevada Bar No. 11711
3770 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169
Attorneys for Defendant Isaiah Smith

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ORDER

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IT IS SO ORDERED:
9/27/2023
DATED:___________________

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UNITED STATES MAGISTRATE JUDGE

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