Jackson v. State of Nevada et al

Filing 138

ORDER Granting 137 Stipulation to Extend Status Report Deadline. Status Report due by 6/12/2023. Signed by Judge Andrew P. Gordon on 5/1/2023. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:16-cv-00995-APG-NJK Document 138 Filed 05/01/23 Page 1 of 2

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Emily A. Buchwald, Esq., Bar No. 13442
[e-mail]:[e-mail]

PISANELLI BICE PLLC

400 South 7th Street, Suite 300
Las Vegas, Nevada 89101
Telephone: [phone]
Attorney for Plaintiff Robert Jackson

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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PISANELLI BICE
400 SOUTH 7TH STREET, SUITE 300
LAS VEGAS, NEVADA 89101

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Case No.:

ROBERT JACKSON
Plaintiff,

v.

2:16-CV-00995-APG-NJK

STIPULATION TO EXTEND
DEADLINES IN STATUS REPORT
(ECF NO. 135)

STATE OF NEVADA, et al.,
Defendant(s).

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Plaintiff Robert Jackson ("Mr. Jackson"), by and through his undersigned counsel, and

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Defendants State of Nevada, et al., ("Defendants"), by and through their undersigned counsel,

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hereby stipulate and agree to extend the time to confer in an attempt to resolve the outstanding

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issues of fees and costs, as set forth in the Status Report filed February 27, 2023. (ECF No. 135.)

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The parties have been negotiating regarding the attorneys' fee and cost award in good

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faith, but have been unable to reach an agreement. The parties believe that additional time may

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assist the parties in reaching an agreement without the assistance of the Court.

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Accordingly, on or before June 12, 2023, if the parties cannot reach an agreement

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regarding the outstanding issues of fees and costs, Plaintiff shall file a motion for fees and costs.

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In addition, Defendants reserve the right to file their own motion for fees and costs and to file an

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appropriate opposition to any motion Plaintiff may file. Alternatively, if the parties are able to

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reach an agreement, on or before June 12, 2023, the parties shall submit a proposed form of final

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judgment.

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Case 2:16-cv-00995-APG-NJK Document 138 Filed 05/01/23 Page 2 of 2

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This is the first stipulation for an extension of time to confer regarding the outstanding

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issues of fees and costs. The Parties represent that this stipulation is sought in good faith, is not

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interposed for delay, and is not filed for an improper purpose. Accordingly, the deadline set forth

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in the Status Report shall be extended as follows:
Deadline for the parties to file a proposed form of final judgment or status report or for

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Plaintiff to file a motion for attorneys' fees and costs: June 12, 2023.

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DATED this 27th day of April 2023

DATED this 27th day of April 2023

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By:

By:

PISANELLI BICE
400 SOUTH 7TH STREET, SUITE 300
LAS VEGAS, NEVADA 89101

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/s/ Emily A. Buchwald
Emily A. Buchwald, Esq., Bar No. 13442

PISANELLI BICE PLLC

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400 South 7th Street, Suite 300
Las Vegas, Nevada 89101

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Attorneys for Defendant Robert Jackson

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/s/ D. Randall Gilmer
D. Randall Gilmer, Esq., Bar No. 14001
Leo T. Hendges, Esq., Bar No. 16034
Office of the Attorney General
Grant Sawyer Bldg.
555 E. Washington Ave. Suite 3900
Las Vegas, Nevada 89101

Attorney for Defendants Jennifer Nash and
Brian Williams

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IT IS SO ORDERED.

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UNITED STATES DISTRICT JUDGE

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DATED: May 1, 2023

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CASE NO. 2:16-CV-00995-APG-NJK

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