Kiessling v. Rader et al

Filing 49

ORDER Granting 48 Stipulation for Extension of Time for Dispositive Motions (First Request). Motions due by 6/1/2017. Signed by Magistrate Judge Nancy J. Koppe on 4/17/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:16-cv-00690-GMN-NJK Document 48 Filed 04/17/17 Page 1 of 2

1 ROBERT W. FREEMAN
Nevada Bar No. 3062
2 [e-mail]
NOEL E. EIDSMORE
3 Nevada Bar No. 7688
[e-mail]
4 CAYLA WITTY
Nevada Bar No. 12897
5 [e-mail]
LEWIS BRISBOIS BISGAARD & SMITH LLP
6 6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
7 702.893.3383
FAX: [phone]
Attorneys for Defendants
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Las Vegas Metropolitan Police
Department, Detective Reggie Rader
9
and Lt. Bobby Smith
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA, SOUTHERN DIVISION
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***
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JAMES KIESSLING,
CASE NO. 2:16-cv-0690-GMN-NJK
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Plaintiff,
PROPOSED STIPULATION AND ORDER
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TO EXTEND THE DEADLINES FOR
vs.
DISPOSITIVE MOTIONS
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DET. RADER P#6099, individually and as a
FIRST REQUEST
17 police officer employed by the Las Vegas
Metropolitan Police Department; LT. B.
18 SMITH, individually and as a police officer
employed by the Las Vegas Metropolitan
19 Police Department; and LAS VEGAS
METROPOLITIAN POLICE
20 DEPARTMENT, a Political Subdivision of the
State of Nevada, inclusive,
21
Defendants.
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Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of

24 record, hereby stipulate and request that this Court extend the deadline to file dispositive motions
25 in the above-captioned case thirty (30) days, up to and including June 1, 2017.
26

This Request for an extension of time is not sought for any improper purpose or other

27 purpose of delay. This request for extension is based upon the following:

LEWIS

28 / / /

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4821-6747-6294.1

Case 2:16-cv-00690-GMN-NJK Document 48 Filed 04/17/17 Page 2 of 2

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Counsel for Defendant has been in out of state depositions in other matters (and has more

2 scheduled) for part of April, and needs additional time to complete Defendant’s motion for
3 summary judgment in this matter. The parties are also awaiting decisions regarding discovery
4 matters in this case.
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Counsel for the parties have met and conferred on this topic and have agreed that, to best

6 serve the interests of the parties and obviate the potential for future motion practice, the most
7 efficient remedy is to reasonably extend the dispositive motion deadline for both parties.
8

WHEREFORE, the parties respectfully request that this Court extend the time for the

9 parties to file their dispositive motions by thirty (30) days from the current deadline of May 1,
10 2017 up to and including June 1, 2017.
11

DATED this 17th day of April, 2017.

DATED this 17th day of April, 2017.

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LEWIS BRISBOIS BISGAARD
& SMITH

GENTILE CRISTALLI, MILLER
ARMENI, SAVARESE

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/s/ Robert W. Freeman
Robert W. Freeman, Jr., Esq.
Nevada Bar No. 3062
Noel E. Eidsmore, Esq.
Nevada Bar No. 7688
Cayla Witty, Esq.
Nevada Bar No. 12897
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendants
Las Vegas Metropolitan Police Department,
Detective Reggie Rader
and Lt. Bobby Smith

/s/ Paola M. Armeni
Paola M. Armeni, Esq.
Nevada Bar No. 8357
Kory L. Kaplan
Nevada Bar No. 13164
410 S. Rampart Blvd., Suite 420
Las Vegas, Nevada 89145
Attorneys for Plaintiff
James Kiessling

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ORDER

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IT IS SO ORDERED.
April 17
Dated this ___ day of ______________, 2017.

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______________________________
U.S. States Magistrate JUDGE
United DISTRICT COURT Judge

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LEWIS

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BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4821-6747-6294.1

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