Dittmar v. City of North Las Vegas

Filing 216

ORDER Granting 215 Stipulation for Extension of Time re 204 Motion for Attorney Fees, Responses due by 5/3/2024. Signed by Judge Jennifer A. Dorsey on 4/22/2024. (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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*****

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PAMELA DITTMAR,
Plaintiff,

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v.

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CITY OF NORTH LAS VEGAS, a municipal
corporation,
Defendant.

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Case No. 2:17-cv-02916-JAD-BNW
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR PLAINTIFF
TO FILE HER RESPONSE TO
MOTION FOR ATTORNEYS’ FEES
[ECF NO. 204]
(Third Request)

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

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

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Todd Creer, Kaitlin H. Paxton, and Kamer Zucker Abbott, who hereby stipulate that the deadline for

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Plaintiff to file her response to Defendant’s Motion for Attorneys’ Fees [ECF No. 204] be extended

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two weeks from the current deadline of April 19, 2024 to May 3, 2024. This stipulation is filed

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pursuant to Local Rule IA 6-1.

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STIPULATION TO EXTEND DEADLINE TO FILE RESPONSE TO MOTION FOR ATTORNEYS’ FEES

This is the third request for an extension of this deadline.

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The first request was due to

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counsel’s schedule and other case commitments after trial and travel that coincided with the original

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deadlines. The second request was due to the parties’ participation in the Ninth Circuit mediation

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program for the appeal of this case.

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participation in the Ninth Circuit mediation program because if the case is resolved it will also

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resolve this pending motion. In support of this stipulation for extension of this deadline, the parties

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state as follows:

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1.

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This third request is also due to the parties continued

The current requested deadline for Plaintiff to file her response to Defendant’s

Motion for Attorneys’ Fees [ECF No. 204] is April 19, 2024. There was a timely motion to continue
the deadline [ECF No. 212] filed on April 5, 2024 that remains pending.
2.

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The parties seek this stipulation of Plaintiff’s response deadline to the motion for

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attorneys’ fees because the parties are in the middle of a Ninth Circuit mediation of the appeal of this

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case that will impact the attorneys’ fees motion and Plaintiff’s need to respond to it in the event the

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case is resolved. If the mediation resolves the appeal of this case, it could also moot this motion for

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attorneys’ fees. For these reasons, as well as the good cause articulated herein, the parties have

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stipulated to extend the deadline for Plaintiff to file her response to Defendant’s Motion for

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Attorneys’ Fees [ECF No. 204].
3.

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Based on the foregoing, the parties stipulate to extend Plaintiff’s deadline to respond

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to Defendant’s Motion for Attorneys’ Fees [ECF No. 204] for two additional weeks from April 19,

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2024 to May 3, 2024.
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This stipulation for an extension of Plaintiff’s response deadline is brought in good

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faith, establishing good cause, and is not sought for any improper purpose or other purpose of delay.

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The parties stipulated to extend the response deadline to provide the parties with sufficient time to

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determine if this case can be resolved through the Ninth Circuit mediation program.
5.

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Through this stipulation, the parties request that the Court extend the deadline for

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Plaintiff to file her response to Defendant’s Motion for Attorneys’ Fees from the current deadline of

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April 19, 2024 that Plaintiff requested by motion for extension [ECF No. 212] to May 3, 2024.

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STIPULATION TO EXTEND DEADLINE TO FILE RESPONSE TO MOTION FOR ATTORNEYS’ FEES