Criminal Productions, Inc. v. Does

Filing 73

ORDER Granting 72 Second Stipulation for Extension of Time Re: 62 Motion to Vacate and 71 Amended Motion to Vacate. Defendant Tracy Cordoba's Responses due by 6/26/2018. Signed by Judge James C. Mahan on 6/15/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-02704-JCM-PAL Document 72 Filed 06/13/18 Page 1 of 3

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F. Christopher Austin (Nevada Bar No. 6559)
[e-mail]
WEIDE & MILLER, LTD.
10655 Park Run Drive, Suite 100
Las Vegas, NV 89144
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Criminal Productions, Inc.

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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CRIMINAL PRODUCTIONS, INC., a Nevada Case No.: 2:16-cv-02704-JCM-PAL
Corporation,

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STIPULATION AND ORDER TO SET
BRIEFING SCHEDULE ON AMENDED
MOTION TO VACATE JUDGMENT
(ECF 71)

Plaintiff,
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v.
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MARIA JENKINS, an individual;
KIMBERLY CRAWFORD, an individual;
CHRISTINA SUTTON, an individual;
JULIUS LENON, an individual; JOSEPH
SMITH, an individual; TRACY CORDOBA,
an individual; MILES PILLUS, an individual;
RAIMOND PEREZ, an individual.

(Second Request)

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Defendants.

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Pursuant to Local Rule IA 6-1(a), Plaintiff Criminal Productions, Inc. (“Plaintiff” or

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“CPI”) and Defendant Tracy Cordoba (“Defendant” or “Cordoba”), by and through their

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undersigned counsel, stipulate to an order resetting the briefing schedule on CPI’s Motion to

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Vacate (ECF 62) to commence from CPI’s amendment to that Motion (ECF 71). This stipulation

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will have the effect of extending the deadline for Defendant to file her Opposition to Plaintiff’s

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Motion to Vacate Judgment Awarding Attorneys’ Fees and Costs (ECF 62, as amended by ECF

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71) from, June 14, 2018 to June 26, 2018. This is the second request for such an extension.

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LR IA 6-1 provides that stipulations to extend may be granted upon a showing of good

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cause when brought prior to the expiration of the relevant deadline. LR IA 6-1(a). There is good

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cause to extend deadlines to provide responding parties with an equitable amount of time to

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W EIDE & MILLER, LTD.
10655 PARK RUN DRIVE
SUITE 100
LAS VEGAS,
NEVADA 89144
[phone]

FCA-w-0724

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Stipulation and Order to Set Briefing

Case 2:16-cv-02704-JCM-PAL Document 72 Filed 06/13/18 Page 2 of 3

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respond to amended pleadings or motions after they have stayed action in responding to the same

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on representations of the filing party that an amendment to the filing may be forthcoming. Such

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is the case here.

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The Parties stipulated to the first extension (ECF 69) on the representation of Plaintiff’s

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counsel that Plaintiff may amend or narrow Plaintiff’s Motion to Vacate. The process of assessing

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issues raised by Defense Counsel, conferring with prior counsel and Plaintiff took longer than the

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Parties originally intended, such that Plaintiff was unable to file its Amended Motion to Vacate

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(ECF 71) until after close of business on June 12, 2018, two days before Defendants extended

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deadline to file its opposition.

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During the interim, Defense Counsel reasonably refrained from drafting an opposition, as

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the motion to which it was to be filed might be amended, and Plaintiff’s counsel represented that

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as an amendment would likely be forthcoming, Plaintiff would stipulate to extend such a deadline

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to provide Defense counsel with a reasonable amount of time to assess and respond to an amended

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motion. The Amended Motion (ECF 71) removed the second argument of the original motion

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(ECF 62) challenging the extent and legitimacy of the attorney’s fees charged, but it left the

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primary arguments in support of that portion of the Motion seeking to vacate the judgment

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awarding attorneys’ fees under Rule 60(b) unmodified. However, it was not until the day prior to

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the deadline that Defense counsel could have known that to prepare an opposition, necessitating

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this stipulation.

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W EIDE & MILLER, LTD.
10655 PARK RUN DRIVE
SUITE 100
LAS VEGAS,
NEVADA 89144
[phone]

FCA-w-0724

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Stipulation and Order to Set Briefing

Case 2:16-cv-02704-JCM-PAL Document 72 Filed 06/13/18 Page 3 of 3

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Good cause, therefore, exists, and this stipulation to reset the opposition deadline from the
June 12, 2018, filing of the Amended Motion (ECF 71) to June 26, 2018 should be granted.
Dated: June 13, 2018

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WEIDE & MILLER, LTD.

REID RUBINSTEIN BOGATZ

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By: /S/ F. Christopher Austin
F. Christopher Austin, Esq.
[e-mail]
10655 Park Run Drive, Suite 100
Las Vegas, NV 89144

By: /S/ Kerry E. Kleiman
Kerry E. Kleiman, Esq.
[e-mail]
300 South 4th Street, Suite 830
Las Vegas, NV 89101

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Attorney for Plaintiff Criminal Productions, Attorney for Defendant Tracy Cordoba
Inc.

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ORDER

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IT IS SO ORDERED

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June day of
Dated this 15, 2018.

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DISTRICT COURT DISTRICT JUDGE
UNITED STATES JUDGE

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W EIDE & MILLER, LTD.
10655 PARK RUN DRIVE
SUITE 100
LAS VEGAS,
NEVADA 89144
[phone]

FCA-w-0724

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Stipulation and Order to Set Briefing