Dittmar v. City of North Las Vegas

Filing 122

ORDER Granting 120 Stipulation for Extension of Time. Proposed Joint Pretrial Order due by 9/15/2022. Signed by Judge Jennifer A. Dorsey on 8/12/2022, nunc pro tunc to 8/4/22. (Copies have been distributed pursuant to the NEF - JQC)

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1 2 3 4 5 6 7 KAMER ZUCKER ABBOTT R. Todd Creer #10016 Kaitlin H. Paxton #13625 3000 West Charleston Boulevard, Suite 3 Las Vegas, Nevada 89102-1990 Tel: (702) 259-8640 Fax: (702) 259-8646 tcreer@kzalaw.com kpaxton@kzalaw.com Attorneys for Defendant City of North Las Vegas 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA PAMELA DITTMAR, ) ) Plaintiff, ) ) vs. ) ) CITY OF NORTH LAS VEGAS, a municipal ) corporation, ) ) Defendant. ) ______________________________________ ) Case No. 2:17-cv-02916-JAD-BNW STIPULATION AND ORDER FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE (First Request) ECF No. 120 Pursuant to Local Rule IA 6-1 and Local Rule 26-3, the parties, by and through their respective counsel of record, stipulate and request that the Court grant an extension of time to submit their Joint Pretrial Order by six (6) weeks, up to and including September 15, 2022. In support of this Stipulation and Request, the parties state as follows: 1. The Court’s Order of February 24, 2022 stayed the deadline to file the Pretrial Order for ten (10) days following the mandatory settlement conference. [ECF No. 116]. 2. The mandatory settlement conference was held on July 25, 2022, and the case did not resolve. Accordingly, the current deadline for the Joint Pretrial Order is August 4, 2022. 3. The parties intend to diligently work to prepare the Joint Pretrial Order. However, counsel for Defendant has pre-scheduled commitments, including out-of-town travel, rendering them KAMER ZUCKER ABBOTT Attorneys at Law 3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • (702) 259-8640 Page 1 of 3 1 unavailable to sufficiently confer with Plaintiff’s counsel to prepare the Joint Pretrial Order by 2 the current deadline. Plaintiff’s counsel also has out-of-town travel plans in August and 3 September for the Labor Day holiday and has requested that if the parties stipulate to extend 4 the current deadline that it be extended until mid-September. 5 4. The parties also need time to meet and confer about issues subject to motions in limine. 6 5. Thus, the parties seek a six (6) week extension of time, up to and including September 15, 7 2022, to submit their Joint Pretrial Order. 8 6. This Request for an extension of time is not sought for any improper purpose or other purpose 9 of delay. Rather, it is sought by the parties solely to allow sufficient time to meet and confer 10 and prepare the Joint Pretrial Order in this case following given that the case did not settle at 11 the mandatory settlement conference as set forth above. 12 7. This is the first request for an extension of time of the Joint Pretrial Order deadline in this 13 matter. 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// KAMER ZUCKER ABBOTT Attorneys at Law 3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • (702) 259-8640 Page 2 of 3 1 2 WHEREFORE, the parties respectfully request that the Court extend the Joint Pretrial Order deadline from August 4, 2022 to September 15, 2022 in this matter. DATED this 29th day of July, 2022. 3 4 Respectfully submitted, Respectfully submitted, 5 MELANIE HILL LAW PLLC KAMER ZUCKER ABBOTT 6 /s/ Melanie A. Hill Melanie A. Hill #8796 1925 Village Center Circle, Suite 150 Las Vegas, Nevada 89134 Tel: (702) 362-8500 Fax: (702) 362-8505 /s/ Kaitlin H. Paxton R. Todd Creer #10016 Kaitlin H. Paxton #13625 3000 West Charleston Boulevard, Suite 3 Las Vegas, Nevada 89102 Tel: (702) 259-8640 Fax: (702) 259-8646 Attorney for Plaintiff Pamela Dittmar Attorneys for Defendant City of North Las Vegas 7 8 9 10 11 12 IT IS SO ORDERED. 13 14 15 8/12/22, nunc pro tunc to 8/4/22 DATE UNITED STATES DISTRICT JUDGE 16 17 18 19 20 21 22 23 24 KAMER ZUCKER ABBOTT Attorneys at Law 3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • (702) 259-8640 Page 3 of 3

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