Sabatini v. Las Vegas Metropolitan Police Department
Filing
36
ORDER granting 35 Stipulation; Motions due by 6/28/2018. Signed by Magistrate Judge Nancy J. Koppe on 6/12/2018. (Copies have been distributed pursuant to the NEF - JM)
1 Marc J. Randazza, NV Bar # 12265
Alex J. Shepard, NV Bar # 13582
2 RANDAZZA LEGAL GROUP, PLLC
2764 Lake Sahara Drive, Suite 109
3 Las Vegas, NV 89117
Telephone: 702-420-2001
4 ecf@randazza.com
5 Attorneys for Plaintiff,
John Sabatini
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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JOHN SABATINI, an individual,
Plaintiff,
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vs.
12 LAS VEGAS METROPOLITAN POLICE
DEPARTMENT,
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Defendant.
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_______________________________________
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CHARLES MOSER,
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Plaintiff,
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vs.
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DEVIN BALLARD, an individual, et al.,
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Case No. 2:17-cv-01012-JAD-NJK
STIPULATION TO EXTEND DEADLINE
TO FILE DISPOSITIVE MOTIONS
(Second Request)
Case No. 2:17-cv-01704-JAD-NJK
Defendants.
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Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective
counsel of record, hereby stipulate and request that this Court extend the
deadline for all parties to file dispositive motions in the above-captioned
Consolidated case for a period of 14 days, up to and including Thursday, June
28, 2018.
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-1Second Stipulation to Extend Deadline to File Dispositive Motions
2:17-cv-01012-JAD-NJK
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In support of this Stipulation and Request, the parties state as follows:
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All discovery in this matter is complete. However, due to scheduling issues
3 and unexpected litigation emergencies, the parties have not been able to
4 dedicate adequate time to preparing the dispositive motions that they plan to
5 file. The current deadline to file dispositive motions is June 14, 2018. The parties
6 plan to file one or more motions for summary judgment and, given the
7 complexity of issues involved in such motions, require additional time to prepare
8 them. The parties expect that a 14-day extension until June 28, 2018 will provide
9 sufficient time.
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Applications to extend any date set by the discovery plan, scheduling
11 order, or other order must, in addition to satisfying the requirements of LR 6-1, be
12 supported by a showing of good cause for the extension. In accordance with
13 LR 26-4, all motions or stipulations to extend a deadline set forth in a discovery
14 plan shall be received by the Court no later than twenty-one (21) days before
15 the expiration of the subject deadline. A request made after the expiration of
16 the subject deadline shall not be granted unless the movant demonstrates that
17 the failure to act was the result of excusable neglect. Any motion or stipulation
18 to extend a deadline or to reopen discovery shall include:
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(a) A statement specifying the discovery completed;
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(b) A specific description of the discovery that remains to be completed;
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(c) The reasons why the deadline was not satisfied or the remaining
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discovery was not completed within the time limits set by the discovery
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plan; and
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(d) A proposed schedule for completing all remaining discovery.
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It is not good cause for a late request to extend discovery that the parties
26 informally postponed discovery. No stipulations are effective until approved by
27 the Court, and “[a]ny stipulation that would interfere with any time set for
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-2Second Stipulation to Extend Deadline to File Dispositive Motions
2:17-cv-01012-JAD-NJK
1 completion of discovery, for hearing of a motion, or for trial, may be made only
2 with approval of the Court.” See LR 7-1(b).
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IT IS SO STIPULATED.
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Dated this 11th day of June 2018.
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RANDAZZA LEGAL GROUP, PLLC
LAW OFFICE OF DANIEL MARKS
/s/ Alex J. Shepard
Marc J. Randazza, NV Bar # 12265
Alex J. Shepard, NV Bar # 13582
RANDAZZA LEGAL GROUP, PLLC
2764 Lake Sahara Drive, Suite 109
Las Vegas, NV 89117
/s/ Adam Levine
Daniel Marks, NV Bar # 2003
Adam Levine, NV Bar # 4673
610 South Ninth Street
Las Vegas, NV 89101
Attorneys for Plaintiff
John Sabatini
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MARQUIS AURBACH COFFING
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Attorneys for Plaintiff
Charles Moser
/s/ Nicholas D. Crosby
Nicholas D. Crosby, NV Bar # 8996
10001 Park Run Drive
Las Vegas, Nevada 89145
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Attorney for Defendants
IT IS SO ORDERED.
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UNITED STATES DISTRICT JUDGE JUDGE
UNITED STATES MAGISTRATE
DATED: June 12, 2018
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-3Second Stipulation to Extend Deadline to File Dispositive Motions
2:17-cv-01012-JAD-NJK
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