Dittmar v. City of North Las Vegas

Filing 128

ORDER Granting 125 and 126 Stipulation for Extension of Time. Signed by Judge Jennifer A. Dorsey on 11/8/2022. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:17-cv-02916-JAD-BNW Document 128 Filed 11/08/22 Page 1 of 3

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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.

Case No. 2:17-cv-02916-JAD-BNW
STIPULATION AND ORDER FOR
EXTENSIONS OF JOINT
PRETRIAL ORDER DEADLINE

CITY OF NORTH LAS VEGAS, a municipal
corporation,

[ECF Nos. 125, 126]

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 requested

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extended deadline of October 19, 2022 up to and including October 26, 2022 pursuant to Local Rule

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IA 6-1 and Local Rule 26-3.

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This is the fourth request for an extension of the Joint Pretrial Order deadline and requests an

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additional week to finalize the final draft of the Joint Pretrial Order. The first request was by

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stipulation to extend the Joint Pretrial Order deadline six weeks to allow the parties time to attend to

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prescheduled commitments given that the case did not resolve at the settlement conference. The

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second request was by stipulation to extend the Joint Pretrial Order deadline to allow sufficient time

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to meet and confer and finalize the Joint Pretrial Order. The third and fourth requests are to allow
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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE

Case 2:17-cv-02916-JAD-BNW Document 128 Filed 11/08/22 Page 2 of 3

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the parties to further revise the final version after numerous meet and confer conferences over the

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last thirty days. The parties have circulated multiple drafts and redlines, however the parties need an

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additional week to review each other’s final redlines, finalize the list of exhibits that the parties will

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mark as Joint Exhibits, and file the final Joint Pretrial Order. This was delayed because after filing

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the third extension request stipulation, plaintiff’s counsel’s daughter got sick and has been out of

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school for the last two days and counsel has been out of work caring for her. In support of this

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

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5. Thus, the parties sought a thirty (30) day extension of time, up to and including October 17,
2022, to submit their Joint Pretrial Order.

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6. The parties have met and conferred multiple times over the last thirty days and circulated

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multiple drafts and redlines, however the parties need an additional week from the last

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requested extension to review each other’s final redlines and file the Joint Pretrial Order.
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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE

Case 2:17-cv-02916-JAD-BNW Document 128 Filed 11/08/22 Page 3 of 3

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7. The parties filed a third stipulation on Monday, October 17, 2022 that has not yet been

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granted and are filing this fourth stipulation requesting a further week extension to allow

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additional time to create a joint Exhibit List or exhibits the parties have agreed should be

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admitted. The parties have circulated multiple drafts and redlines, however the parties need

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an additional week to review each other’s final redlines, finalize the list of exhibits that the

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parties with mark as Joint Exhibits, and file the final Joint Pretrial Order. This was delayed

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because after filing the third extension request stipulation, plaintiff’s counsel’s daughter got

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sick and has been out of school for the last two days and counsel has been out of work caring

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for her.

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8. This request for an extension of time is not sought for any improper purpose or other purpose

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

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other’s final redlines, finalize the list of exhibits that the parties with mark as Joint Exhibits,

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and file the final Joint Pretrial Order in light of the delay caused by plaintiff’s counsel’s

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daughter’s illness and her being out of work caring for her daughter.

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

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deadline from October 19, 2022 up to and including October 26, 2022 in this matter.
DATED this 19th day of October, 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

Based on the parties' stipulations [ECF Nos. 125, 126] and good cause appearing, IT IS SO
ORDERED.
11/8/22
DATE

UNITED STATES DISTRICT JUDGE
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STIPULATION AND REQUEST FOR EXTENSION OF JOINT PRETRIAL ORDER DEADLINE