Cosio v. State of Nevada ex. rel. Nevada Department of Transportation

Filing 24

ORDER Granting 22 Motion to Extend Time re 21 Order - Discovery Plan and Scheduling Order (First Request). Motions due by 5/29/2018. Signed by Magistrate Judge Peggy A. Leen on 5/8/2018. (Copies have been distributed pursuant to the NEF - MR)

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ADAM PAUL LAXALT
Attorney General
DOMINIKA J. BATTEN
Deputy Attorney General
Nevada Bar No. 12258
KEVIN A. PICK
Deputy Attorney General
Nevada Bar No. 11683
State of Nevada
Office of the Attorney General
5420 Kietzke Lane, Suite 202
Reno, NV 89511
[phone] (phone)
[phone] (fax)
Email: [e-mail]
[e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CHRISTINE COSIO,

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Plaintiff,

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Case No. 2:17-cv-01940-JAD-PAL

vs.
STATE OF NEVADA ex rel. NEVADA
DEPARTMENT OF TRANSPORTATION,
a political subdivision of the State of Nevada;
DOES I through V, inclusive; and ROES
corporations I through V, inclusive,

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Defendants.

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MOTION TO EXTEND DEADLINE
FOR DISPOSITIVE MOTIONS
(FIRST REQUEST TO EXTEND
DEADLINE FOR DISPOSITIVE
MOTIONS, SECOND REQUEST TO
EXTEND DEADLINES IN
STIPULATED DISCOVERY PLAN
AND SCHEDULING ORDER)

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Defendant,

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STATE

OF

NEVADA

ex

rel.

NEVADA

DEPARTMENT

OF

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TRANSPORTATION (“NDOT”), by and through its legal counsel, ADAM PAUL LAXALT,

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Attorney General, DOMINIKA J. BATTEN, Deputy Attorney General, and KEVIN A. PICK,

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Deputy Attorney General, hereby submit this Motion to Extend the May 7, 2018, Deadline for

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Dispositive Motions, pursuant to Local Rules IA 6-1, IA 6-2, and 26-4.

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This is the Defendant’s first request to extend the deadline for dispositive motions and

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the second request to extend deadlines set forth in the Stipulated Discovery Plan and Scheduling

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Order, the first such request having been by stipulation between the parties. See ECF No. 21.

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On October 10, 2017, this Court entered an Order granting the Discovery Plan and

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Scheduling Order submitted by the parties. See ECF No. 12. The parties then filed a stipulated

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request to amend the Court’s Scheduling Order and specifically requested a sixty (60) day

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extension to the discovery deadline. See ECF No. 20. The stipulated extension of the discovery

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deadline was granted by the Court and the deadline for dispositive motions was necessarily

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extended as well.

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The Defendant now requests a three (3) week extension of the deadline for dispositive

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motions, which is currently set to expire on May 7, 2018. Good cause exists to grant this

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requested extension due a death in the immediately family of Deputy Attorney General,

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Dominika J. Batten, who is the primary/handling attorney assigned to this case. This request for

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an extension of time is made in good faith, and not for the purpose of undue delay. If granted,

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the new deadline for dispositive motions would be May 29, 2018 (May 28, 2018, is a Federal

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holiday). Based on the foregoing, the Defendant respectfully requests that the deadline for

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dispositive motions be extended an additional three (3) weeks.

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DATED: April 26, 2018
ADAM PAUL LAXALT
Attorney General

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By:
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/s/ Kevin A. Pick
KEVIN A. PICK, ESQ.
Deputy Attorney General
Nevada Bar No. 11683
Attorneys for Defendants

ORDER

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IT IS SO ORDERED.

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May 8
Dated: __________________________, 2018

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___________________________________
U.S. Magistrate Judge

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CERTIFICATE OF SERVICE

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Pursuant to Fed. R. Civ. P. 5(b), the undersigned hereby certifies that she is an

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employee of the State of Nevada Office of the Attorney General and is a person of such age and

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discretion as to be competent to serve papers. That on this date, the undersigned filed a true and

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accurate copy of the foregoing MOTION TO EXTEND DEADLINE FOR DISPOSITIVE

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MOTIONS with the United States District Court, using the CM/ECF Electronic Filing, which

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will e-serve the following parties electronically:

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Andrew L. Rempfer
10091 Park Run Drive, Suite 200
Las Vegas, NV 89145-8868
[e-mail]
Attorney for Plaintiff
Dated this 26th day of April, 2018.

/s/ Ginny Brownell
Ginny Brownell, an employee of
the office of the Nevada Attorney General

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