Rivera v. Daniel Bogden, et al

Filing 49

ORDER Granting 48 Stipulationto Extend Time Re: 47 Motion for Summary Judgment. Responses due by 5/29/2019. Replies due by 6/14/2019. Signed by Judge James C. Mahan on 5/29/2019. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-02776-JCM-NJK Document 48 Filed 05/24/19 Page 1 of 2

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MATTHEW Q. CALLISTER, ESQ.
Nevada Bar No.: 1396
[e-mail]
MITCHELL S. BISSON, ESQ.
Nevada Bar No.: 11920
[e-mail]
CALLISTER LAW GROUP
330 E. Charleston Blvd., Suite 100
Las Vegas, NV 89104
Tel.: [phone]
Fax: [phone]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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330 E. Charleston Blvd., Suite 100
Las Vegas, Nevada 89104
T: [phone] F: [phone]

CALLISTER LAW GROUP

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RUDY RIVERA, an individual,
vs.

Plaintiff,

DANIEL BOGDEN, et. al.,
Defendants.

***
Case No.: 2:17-cv-02776-JCM-NJK
STIPULATION AND ORDER TO
EXTEND THE DEADLINE TO
RESPOND TO DEFENDANTS’ MOTION
FOR SUMMARY JUDGMENT

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(First Request)

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COMES NOW, Plaintiff RUDY RIVERA, by and through his counsel of record Mitchell

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S. Bisson, Esq. of the Callister Law Group, and Defendant CORRECTIONS CORPORATION

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OF AMERICA (“CoreCivic”), by and through its counsel of record Jacob. B. Lee, Esq. of Struck

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Love Bojanowski & Acedo, PLC, and hereby respectfully submit this Stipulation and Order to

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Extend the Deadline to Respond to Defendants’ Motion for Summary Judgment (the

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“Stipulation”). This Stipulation is made in accordance with LR IA 6-1, LR IA 6-2, LR 7-1, and

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LR 26-4 of the Local Rules of this Court. This is the first request for an extension of time to file

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the Plaintiff’s response Opposition to Defendants’ Motion for Summary Judgment and

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subsequent Reply from Defendant.

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Defendants filed the Motion for Summary Judgment [Dkt. 47] on May 3, 2019 and
Plaintiffs’ response is currently due May 24, 2019. The instant extension is requested because
Plaintiffs’ counsel unexpectedly had a trial run three days longer than expected, and as a result,

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Case 2:17-cv-02776-JCM-NJK Document 48 Filed 05/24/19 Page 2 of 2

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requires additional time to prepare the response Opposition to Defendants’ Motion. This request

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for an extension of time is not sought for any improper purpose or other purpose of delay. It is

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further requested that the deadline to file Defendant’s Reply be extended as well.

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Upon agreement by and between all parties hereto as set forth herein, the undersigned

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respectfully requests this Court grant an extension of time, up to and including May 29, 2019,

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for Plaintiff to file an Opposition to Defendants’ Motion to Dismiss [Dkt. 47], and to grant an

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extension of time, up to and including June 14, 2019 for Defendant to file a Reply to Plaintiff’s

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response Opposition.

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330 E. Charleston Blvd., Suite 100
Las Vegas, Nevada 89104
T: [phone] F: [phone]

CALLISTER LAW GROUP

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DATED this 24th day of May, 2019.

DATED this 24th day of May, 2019.

CALLISTER LAW GROUP

STRUCK LOVE
ACEDO, PLC

/s/ Mitchell S. Bisson
Matthew Q. Callister, Esq.
Nevada Bar No.: 1396
Mitchell S. Bisson, Esq.
Nevada Bar No.: 11920
Callister Law Group
330 E. Charleston Blvd., Suite 100
Las Vegas, NV 89104
Attorneys for Plaintiff

BOJANOWSKI

/s/ Jacob B. Lee
Rachel Love, Esq.
Jacob B. Lee, Esq.
3100 West Ray Road, Suite 300
Chandler, Arizona 85226
[e-mail]
[e-mail]
Attorneys for Defendant
Corrections Corporation of AmericaCoreCivic

&

_

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ORDER
IT IS SO ORDERED.

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UNITED STATES DISTRICT COURT JUDGE
Dated:

May 29, 2019

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