Dryden v. State of Nevada et al

Filing 256

ORDER granting ECF No. 255 Stipulation for Extension of Time: Proposed Joint Pretrial Order due by 11/17/2023. Signed by Judge Jennifer A. Dorsey on 9/13/2023. (Copies have been distributed pursuant to the NEF - DLS)

Case 2:16-cv-01227-JAD-EJY Document 256 Filed 09/13/23 Page 1 of 2
1
2
3
4
5
6
7
8
9

AARON D. FORD
Attorney General
Lorin M. Taylor, Bar No. 14958
Deputy Attorney General
Victoria C. Corey, Bar No. 16364C
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., Ste 3900
Las Vegas, NV 89101
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant Ted Nielson

10

UNITED STATES DISTRICT COURT

11

DISTRICT OF NEVADA

12

BRYAN DRYDEN,

13

Case No. 2:16-cv-01227-JAD-EJY

Plaintiff,

14

v.

15

STATE OF NEVADA, et al.,

STIPULATION AND ORDER TO
EXTEND PROPOSED JOINT
PRETRIAL ORDER DEADLINE
(THIRD REQUEST)

16

Defendants.

17

Defendant Ted Nielson, by and through counsel, Aaron D. Ford, Nevada Attorney

18

General, and Lorin M. Taylor, Deputy Attorney General, and Victoria C, Corey, Deputy

19

Attorney General; and Plaintiff Bryan Dryden, by and through counsel Justin V. Alper

20

hereby submit their third stipulation and agreement to extend the deadline for dispositive

21

motions and respectfully request that the Court extend the deadline to file a proposed joint

22

pretrial order to November 17, 2023. The Parties are requesting the modification in good

23

faith and the request is supported by good cause.

24

LR 26-3 requires that the extension of any date set by the discovery plan, scheduling

25

order, or other order must—as well as satisfying the requirements of LR IA 6-1 to explain

26

the reasons an extension is needed—demonstrate good cause for the extension.

27

Good cause to extend the deadline to file a proposed joint pretrial order exists.

28

Deputy Attorney General Victoria C. Corey has recently been added to the case in

Page 1 of 2

Case 2:16-cv-01227-JAD-EJY Document 256 Filed 09/13/23 Page 2 of 2
1

preparation to take over when Deputy Attorney General Lorin M. Taylor transfers

2

divisions in October of 2023. Additionally, Deputy Attorney General Lorin M. Taylor has

3

been severely sick over the past few weeks, and was unable to come in office and work for

4

over a week, and she is currently catching up on her deadlines. Lastly, Plaintiff’s Counsel

5

Justin V. Alper requires additional time to prepare a potential exhibit list, as there has

6

been a total of six depositions in this case, an evidentiary hearing including nine witnesses,

7

and hundreds of medical and other institutional documents that Plaintiff’s Counsel needs

8

more time to review. Plaintiff’s Counsel and Defense Counsel have been working well

9

together and believe they can continue working together to attempt to streamline this trial

10

and potentially stipulate to evidence, facts, and potential witnesses.

11

Based on the foregoing, the Parties submit that good cause exists to grant the

12

requested extension and that the deadline to submit a proposed joint pretrial order be

13

moved to November 17, 2023.

14
DATED this 7th day of September, 2023
and respectfully submitted by:
AARON D. FORD
Attorney General

DATED this 7th day of September, 2023
and approved as to form and content by:

20

/s/ Victoria C. Corey
LORIN M. TAYLOR (Bar No. 14958)
VICTORIA C. COREY (Bar No. 16364C)
555 E. Washington Avenue, Suite 3900
Las Vegas, NV 89101
[e-mail]

/s/ Justin V. Alper
JUSTIN V. ALPER, (Bar No. 12923C)
3535 Executive Terminal Dr. #300
Henderson, NV 89052
[e-mail]

21

Attorneys for Defendant

15
16
17
18
19

Attorney for Plaintiff

22
23

IT IS SO ORDERED:

24
25
26
27
28

UNITED STATES DISTRICT JUDGE
Dated:

9-13-23

Page 2 of 2