Does v. Laxalt et al

Filing 123

ORDER granting 122 STIPULATION (First Request) TO CONTINUE Calendar Call and Trial Dates. Calendar Call is reset for 3/3/2020 at 10:00 AM in LV Courtroom 7C before Judge Richard F. Boulware II. Jury Trial is reset for 3/10/2020 at 09:00 AM in LV Courtroom 7C before Judge Richard F. Boulware II. Signed by Judge Richard F. Boulware, II on 1/17/2020. (Copies have been distributed pursuant to the NEF - DRS)

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1 2 3 4 5 6 7 8 ROBERT M. DRASKOVICH, ESQ. Nevada Bar No. 6275 THE DRASKOVICH LAW GROUP 815 S. Casino Center Boulevard Las Vegas, Nevada 89101 Telephone: (702) 474-4222 GARY A. MODAFFERI, ESQ. Nevada Bar No. 12450 LAW OFFICE OF GARY A. MODAFFERI, LLC 612 S. 3rd Street, Suite A Las Vegas, Nevada 89101 Telephone: (702) 327-3033 9 10 11 12 13 14 ALLEN LICHTENSTEIN, ESQ. Nevada Bar No. 3992 3315 E. Russell Road Las Vegas, Nevada 89120 Attorney for Plaintiffs Telephone (702) 433-2666 Attorneys for Plaintiffs 15 UNITED STATES DISTRICT COURT 16 DISTRICT OF NEVADA 17 18 19 20 DOES 1-35; and UNKNOWN NAMED DOES 1-1000, Plaintiffs, v. AARON FORD, Attorney General of the State of Nevada; et al; 21 22 Defendants. ) CASE NO.: 2:15-CV-01638-RFB-CWH ) ) ) STIPULATION TO CONTINUE ) CALENDAR CALL AND TRIAL DATES ) ) ) ) 23 24 IT IS HEREBY STIPULATED AND AGREED by and between AARON FORD, 25 26 27 28 Attorney General, and ADAM HONEY, counsel for Defendants; ROBERT M. DRASKOVICH, counsel for Plaintiffs, that the calendar call currently scheduled for January 21, 2020 at the hour 1 2 of 3:00 p.m. and the trial currently scheduled for January 27, 2020 at 9:00 a.m. be vacated for at least ninety (90) days and set to a date and time convenient to the Court. 3 This Stipulation is entered into for the following reasons: 4 5 6 1. There are outstanding motions still to be decided by this Honorable Court. 2. Denial of this request for continuance would deny counsel for the defendant 7 sufficient time within which to be able to effectively and thoroughly research this case, 8 taking into account the exercise of due diligence. 9 3. Additionally, denial of this request for continuance could result in a miscarriage of 10 11 12 13 justice. 4. The additional time requested by this Stipulation is excludable in computing the time within which the trial herein must commence pursuant to the Speedy Trial Act, Title 18, United 14 States Code §§ 3161(h)(7)(A), Title 18, United States Code § 3161(h)(7)(B)(i) and 15 16 3161(h)(7)(B)(iv). 17 This is the first request to continue trial date filed herein. 18 DATED this 15th day of January, 2020. 19 AARON FORD ATTORNEY GENERAL 20 21 22 23 24 25 26 27 28 Allen Lichtenstein /s/___________________________ ALLEN LICHTENSTEIN, ESQ. Nevada Bar No. 3992 ROBERT M. DRASKOVICH, ESQ. Nevada Bar No. 6275 GARY A. MODAFFERI, ESQ. Nevada Bar No. 12450 Attorneys for Plaintiffs Adam Honey /s/_____________________________ ADAM HONEY Deputy Attorney General Attorney for Defendants 1 2 /// 3 ORDER 4 5 6 IT IS HEREBY ORDERED that the calendar call currently schedule for January 21, 2020 March 3, 2020 at the hour of 3:00 p.m. be vacated and continued to ______________________ at the hour of 7 ____________, and the trial currently scheduled for January 27, 2020 at 9:00 a.m. be vacated 10:00 AM 8 9:00 AM March 10, 2020 and continued to _____________________ at the hour of _____________. 9 10 17th DATED AND DONE this ____ day of January, 2020. 11 _________________________________ RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Respectfully Submitted By: /s/ Allen Lichtenstein _______________________________ ALLEN LICHTENSTEIN, ESQ. Nevada Bar No. 3992 ROBERT M. DRASKOVICH, ESQ. Nevada Bar No. 6275 GARY A. MODAFFERI, ESQ. Nevada Bar No. 12450 Attorneys for Plaintiffs

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