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)

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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 6 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 7 8 9 JOHN SABATINI, an individual, Plaintiff, 10 11 vs. 12 LAS VEGAS METROPOLITAN POLICE DEPARTMENT, 13 Defendant. 14 _______________________________________ 15 CHARLES MOSER, 16 Plaintiff, 17 vs. 18 DEVIN BALLARD, an individual, et al., 19 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. 20 21 22 23 24 25 26 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. 27 28 -1Second Stipulation to Extend Deadline to File Dispositive Motions 2:17-cv-01012-JAD-NJK 1 In support of this Stipulation and Request, the parties state as follows: 2 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. 10 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: 19 (a) A statement specifying the discovery completed; 20 (b) A specific description of the discovery that remains to be completed; 21 (c) The reasons why the deadline was not satisfied or the remaining 22 discovery was not completed within the time limits set by the discovery 23 plan; and 24 (d) A proposed schedule for completing all remaining discovery. 25 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 28 -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). 3 IT IS SO STIPULATED. 4 Dated this 11th day of June 2018. 5 6 7 8 9 10 11 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 12 MARQUIS AURBACH COFFING 13 Attorneys for Plaintiff Charles Moser /s/ Nicholas D. Crosby Nicholas D. Crosby, NV Bar # 8996 10001 Park Run Drive Las Vegas, Nevada 89145 14 15 16 17 Attorney for Defendants IT IS SO ORDERED. 18 19 20 21 22 UNITED STATES DISTRICT JUDGE JUDGE UNITED STATES MAGISTRATE DATED: June 12, 2018 23 24 25 26 27 28 -3Second Stipulation to Extend Deadline to File Dispositive Motions 2:17-cv-01012-JAD-NJK

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