Dittmar v. City of North Las Vegas

Filing 24

ORDER granting 23 Stipulation to Extend Time. Amended Complaint deadline: 9/7/2018. Signed by Judge Jennifer A. Dorsey on 8/27/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:17-cv-02916-JAD-PAL Document 23 Filed 08/24/18 Page 1 of 2

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MELANIE A. HILL, ESQ.
Nevada Bar No. 8796
MELANIE HILL LAW PLLC
520 S. 7th Street, Suite A
Las Vegas, NV 89101
Tel: [phone]
Fax: [phone]
[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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Case No. 2:17-cv-02916-JAD-PAL

PAMELA DITTMAR,
Plaintiff,

STIPULATION TO EXTEND
DEADLINE FOR PLAINTIFF TO
FILE HER AMENDED COMPLAINT
TO FURTHER CONFER ON
PLAINTIFF’S CLAIMS

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

(First Request)

Defendant.

ECF No. 23

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Counsel for Plaintiff, Melanie A. Hill of Melanie Hill Law PLLC, and counsel for Defendant,

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R. Todd Creer and Kaitlin H. Paxton of the law firm of Kamer Zucker Abbott, respectfully submit

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the following stipulation to extend the deadline for Plaintiff to file her amended complaint to further

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meet and confer on Plaintiff’s amended claims. The parties make this joint request to extend the

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deadline for Plaintiff to file her amended complaint to allow the parties additional time meet and

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confer on the claims Plaintiff will pursue in her amended complaint and meaningfully discuss the

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arguments raised in Defendant’s Motion to Dismiss [ECF No. 8] that was denied without prejudice

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“to the City’s right to reurge it after Dittmar files her amended complaint.” [ECF No. 14].

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1. Plaintiff Pamela Dittmar received her right to sue letter from NERC/EEOC for her

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second charge of discrimination filed with the Nevada Equal Rights Commission

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(“NERC”) on or about July 23, 2018.

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STIPULATION TO EXTEND DEADLINE

Case 2:17-cv-02916-JAD-PAL Document 23 Filed 08/24/18 Page 2 of 2

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2. Counsel for both parties are requesting additional time to meaningfully meet and confer

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and allow Defendant City of North Las Vegas to review Plaintiff’s draft amended

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complaint before it is filed in an attempt to work out any legal issues to eliminate the

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need to file a new motion to dismiss.

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3. The requested extension is not for purposes of delay, but to avoid unnecessary litigation

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or the wasting of resources and expense on issues that can be resolved between the

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parties or through further amendment of the complaint before it is filed.
WHEREFORE, the parties respectfully request that the Court extend Plaintiff’s deadline to

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file her amended complaint two weeks until September 7, 2018.
DATED this 24th day of August, 2018.

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MELANIE HILL LAW PLLC

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By:

KAMER ZUCKER ABBOTT

/s/ Melanie A. Hill
Melanie A. Hill, Esq.
NV Bar No. 8796
520 S. 7th Street, Suite A
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff Pamela Dittmar

By:

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

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IT IS SO ORDERED.
Dated this _______ day of August, 2018.
_______________________________
________________
_ _
__ _
U.S. District Jud e Jennifer A Dorsey
rict Ju
t Judg Jennifer A.
Judge nnif
nn
____________________________________
August 27, 2018 DORSEY
JENNIFER A.
UNITED STATES DISTRICT COURT JUDGE

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STIPULATION TO EXTEND DEADLINE