Dittmar v. City of North Las Vegas

Filing 124

ORDER Granting 123 Stipulation for Extension of Time. Proposed Joint Pretrial Order due by 10/17/2022. Signed by Judge Jennifer A. Dorsey on 10/3/2022. (Copies have been distributed pursuant to the NEF - JQC)

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MELANIE A. HILL, ESQ.
Nevada Bar No. 8796
MELANIE HILL LAW PLLC
1925 Village Center Circle, Suite 150
Las Vegas, NV 89134
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff Pamela Dittmar

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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PAMELA DITTMAR,

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Plaintiff,
v.
CITY OF NORTH LAS VEGAS, a municipal
corporation,

Case No. 2:17-cv-02916-JAD-BNW
STIPULATION AND REQUEST FOR
EXTENSION OF JOINT PRETRIAL
ORDER DEADLINE
(Second Request)

ECF No. 123

Defendant.

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NOW COMES the Plaintiff, Pamela Dittmar, by and through her attorneys, Melanie A.

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Hill and Melanie Hill Law PLLC, and Defendant, City of North Las Vegas, by and through its

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attorneys, R. Todd Creer, Kaitlin H. Paxton, and Kamer Zucker Abbott, who hereby stipulate that

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the deadline for the parties to file their Joint Pretrial Order be extended from the current deadline of

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September 15, 2022 up to and including October 17, 2022 pursuant to Local Rule IA 6-1 and Local

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Rule 26-3.

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This is the second request for an extension of the Joint Pretrial Order deadline. The first

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request was by stipulation to extend the Joint Pretrial Order deadline six weeks to allow the parties

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time to attend to prescheduled commitments given that the case did not resolve at the settlement

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conference. In support of this Stipulation and Request, the parties state as follows:

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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].
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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE

2. The mandatory settlement conference was held on July 25, 2022 and the case did not resolve.

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Accordingly, the deadline for the Joint Pretrial Order was August 4, 2022.

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3. The parties stipulated to extend the Joint Pretrial Order deadline six weeks due to counsel for

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Defendant’s pre-scheduled commitments, including out-of-town travel, rendering them

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unavailable to sufficiently confer with Plaintiff’s counsel to prepare the Joint Pretrial Order

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by the current deadline. The stipulation was a little longer to account for Plaintiff’s counsel’s

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out-of-town travel plans in September for the Labor Day holiday.

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4. Counsel for Plaintiff was brought in at the last minute to assist in a two-week federal trail in

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late August that delayed Plaintiff’s completion of the Joint Pretrial Order and meet and

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confer. Further, Counsel for Defendant have had to attend multiple hearings scheduled with

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short notice, one of which required immediate briefing, in addition to tending to a family

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emergency. Therefore, due to Plaintiff’s counsel’s schedule in late August and Defendant’s

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counsel’s schedule over the past few weeks, the parties also need additional time to meet and

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confer about issues in the Joint Pretrial Order and issues subject to motions in limine.
5. Thus, the parties seek a thirty (30) day extension of time, up to and including October 17,

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2022, to submit their Joint Pretrial Order.

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6. This Request for an extension of time is not sought for any improper purpose or other

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purpose of delay. Rather, it is sought by the parties solely to allow sufficient time to meet

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and confer and finalize the Joint Pretrial Order in this case.

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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE

WHEREFORE, the parties respectfully request that the Court extend the Joint Pretrial Order

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deadline from September 15, 2022 up to and including October 17, 2022 in this matter.
DATED this 13th day of September, 2022.

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MELANIE HILL LAW PLLC
By:

KAMER ZUCKER ABBOTT

/s/ Melanie A. Hill
Melanie A. Hill, Esq. (NV Bar No. 8796)
1925 Village Center Circle, Ste. 150
Las Vegas, Nevada 89134
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff Pamela Dittmar

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By:

/s/ Kaitlin H. Paxton
R. Todd Creer (NV Bar No. 10016)
Kaitlin H. Paxton (NV Bar No. 13625)
3000 West Charleston Blvd., Suite 3
Las Vegas, Nevada 89102
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant City of North
Las Vegas

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IT IS SO ORDERED.

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10/3/2022
DATE

UNITED STATES DISTRICT JUDGE
nunc pro tunc to 9/15/2022

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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE