Cervantes v. Las Vegas Metropolitan Police Department Detention Service Division et al

Filing 124

ORDER granting ECF No. 123 Stipulation. Plaintiff shall have up to and including May 5, 2021, to respond to the Motion for Reconsideration (ECF No. 122 ). Signed by Chief Judge Miranda M. Du on 4/7/2021. (Copies have been distributed pursuant to the NEF - AB)

TREVOR J. HATFIELD, ESQ
1 Nevada Bar No. 7373
2 HATFIELD & ASSOCIATES, LTD.
703 S. Eighth Street
3 Las Vegas, Nevada 89101
Telephone: [phone]
4 Facsimile: [phone]
5 Email: [e-mail]
Attorney for Plaintiff In Conjunction with Legal Aid Center of
6 Southern Nevada Pro Bono Project
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

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LUIS CERVANTES,
Plaintiff,

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vs.
EDDIE SCOTT, et al.,

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Defendants.

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CASE NO: 2:17-cv-00562-MMD-DJA
STIPULATION AND ORDER TO EXTEND
TIME FOR PLAINTIFF TO RESPOND TO
DEFENDANTS EDDIE SCOTT, KEVIN
PATIMETEEPORN AND TIMOTHY
DORION’S MOTION FOR
RECONSIDERATION OF
THE COURT’S ORDER DENYING
SUMMARY JUDGMENT [ECF No. 117]
(First Request)

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COMES NOW, Plaintiff Luis Cervantes (“Plaintiff”), by and through his counsel, the law
firm of Hatfield & Associates., Ltd., appearing pro bono publico, and Defendants Eddie Scott,

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Kevin Patimeteeporn, and Timothy Dorion (“LVMPD Defendants”) by and through their

22 counsel, the law firm of Kaempfer Crowell, hereby stipulate and agree to extend the time for
23 Plaintiff to Respond to LVMPD Defendants’ Motion for Reconsideration of the Court’s Order
24 Denying Summary Judgment (ECF #117) filed on March 22, 2021.
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Accordingly, Plaintiff shall have up to and including May 5, 2021, to respond to LVMPD
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Defendants’ Motion for Reconsideration of the Court’s Order Denying Summary Judgment
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This request is submitted pursuant to LR IA 6-1, 6-2 and LR II 7-1 and is the parties first

2 request for an extension of time for Plaintiff to respond to Defendant’s Motion for
3 Reconsideration of the Court’s Order Denying Summary Judgment (ECF #117).
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Good cause exists for this extension, as the current coronavirus/COVID-19 pandemic has
caused, and continues to cause, disruption to the practices of counsel involved in this case. In

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addition, Plaintiff is incarcerated in High Desert State Prison and Plaintiff’s Counsel has had

8 difficulty communicating with him to formulate an opposition to Defendant’s Motion for
9 Reconsideration of the Court’s Order Denying Summary Judgment.

703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

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Defendant has courteously granted this first request for an extension of time to file
Plaintiff’s Response. The extension will not prejudice any party and will allow Plaintiff to

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adequately brief its opposition to LVMPD Defendants’ Motion for Reconsideration of the

14 Court’s Order Denying Summary Judgment filed with this Court. The parties are not delaying
15 the conclusion of this matter by way of trial or otherwise; no trial date has yet been ordered,
16 although a Settlement Conference has been ordered for April 21, 2021.
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DATED this 5th day of April, 2021
DATED this 5th day of April, 2021
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HATFIELD & ASSOCIATES
KAEMPFER CROWELL
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/s/ Trevor J. Hatfield
/s/ Lyssa S. Anderson
20 By:
By:
TREVOR J. HATFIELD, ESQ.
LYSSA S. ANDERSON, ESQ.
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Nevada Bar No. 7373
Nevada Bar No. 5781
703 S. Eighth Street
RYAN W. DANIELS, ESQ.
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Las Vegas, Nevada 89101
Nevada State Bar No. 13094
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Tel: [phone]
KRISTOPHER J. KALKOWSKI, ESQ
Email: [e-mail]
Nevada State Bar No. 14892
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Attorney for Plaintiff In Conjunction with
Tel.: [phone]
Legal Aid Center of Southern Nevada Pro
Email: [e-mail]
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Bono Project.
Email: [e-mail]
Email: [e-mail]
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Attorneys for Defendants Eddie Scott, Kevin
Patimeteeporn, and Timothy Dorion
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703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

1 DATED this 5th day of April, 2021
2
LEWIS BRISBOIS BISGAARD & SMITH, LLP
3
/s/ Katherine J. Gordon
4 By:
_________________
S. BRENT VOGEL, ESQ.
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Nevada State Bar No. 6858
6 KATHERINE J. GORDON, ESQ.
Nevada State Bar No. 5813
7 6385 S. Rainbow Boulevard, Suite 600
8 Las Vegas, Nevada 89118
Tel.: [phone]
9 Email: [e-mail]
Email: [e-mail]
10 Attorneys for Defendant Allan Kirkwood, DDS
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16 IT IS SO ORDERED:
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ORDER

MIRANDA M. DU
CHIEF UNITED STATES DISTRICT JUDGE
Dated: THIS 7th Day of April 2021.

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