Dittmar v. City of North Las Vegas

Filing 44

ORDER Granting 43 Stipulation to Stay Proceedings. Signed by Magistrate Judge Brenda Weksler on 5/2/2019. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-02916-JAD-PAL Document 43 Filed 04/26/19 Page 1 of 3

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KAMER ZUCKER ABBOTT
R. Todd Creer
#10016
Kaitlin H. Paxton
#13625
3000 West Charleston Boulevard, Suite 3
Las Vegas, Nevada 89102-1990
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
City of North Las Vegas

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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)
Case No. 2:17-cv-02916-JAD-PAL
)
Plaintiff,
)
STIPULATION AND ORDER TO
STAY PROCEEDINGS PENDING
)
RESOLUTION OF THE PARTIES’
vs.
)
MOTIONS REGARDING THE
)
DEPOSITIONS OF MAYOR JOHN
CITY OF NORTH LAS VEGAS, a municipal )
LEE AND CITY MANAGER RYANN
corporation,
)
JUDEN
)
Defendant.
)
(First Request)
)
Plaintiff Pamela Dittmar (“Plaintiff”), by and through her counsel, Melanie Hill Law PLLC,

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and Defendant City of North Las Vegas (“Defendant”), by and through its counsel, Kamer Zucker

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Abbott, stipulate and request that the Court stay these proceedings pending resolution of Plaintiff’s

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Motion to Compel Depositions of Mayor John Lee and Ryann Juden (ECF No. 38) and Defendant’s

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Motion for Protective Order as to the Requested Depositions of Mayor John Lee and City Manager

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Ryann Juden (ECF No. 36). In support of this Stipulation and Request, the parties state as follows:

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PAMELA DITTMAR,

1.

On March 12, 2019, the parties stipulated to a briefing schedule for the motions

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regarding the depositions of Mayor John Lee (“Lee”) and City Manager Ryann Juden (“Juden”), which

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was approved by the Honorable Magistrate Judge Peggy A. Lee on March 14, 2019 (ECF No. 33).

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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Case 2:17-cv-02916-JAD-PAL Document 43 Filed 04/26/19 Page 2 of 3

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2.

Defendant filed its opening brief on March 22, 2019 and Plaintiff filed her opening

brief on March 23, 2019.

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3.

Both parties filed their response briefs on March 30, 2019 (ECF Nos. 41 and 42).

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4.

A hearing has thus far not been ordered on this dispute nor has a decision been issued.

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5.

As acknowledged in the stipulation, the parties agreed to not hold the Lee and Juden

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depositions until after a decision has been rendered. Likewise, other discovery dependent on the

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outcome of whether the depositions will take place has also been paused.

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6.

without knowing when the motions will be decided and in an effort to conserve expenditures and
resources, the parties seek to stay all proceedings until the motions are decided.

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The parties have extended discovery twice. Rather than ask for additional extensions

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Once the Court has ruled on the motions, the parties will work cooperatively together

to submit appropriate deadlines to complete discovery and continue to move this case forward.

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8.

This request to stay proceedings is not sought for any improper purpose or other

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reason of delay. Rather, it is sought only to conserve the parties’ respective resources and efficiently

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conduct discovery while awaiting the Court’s decision on the motions regarding the Lee and Juden

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depositions.

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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Case 2:17-cv-02916-JAD-PAL Document 43 Filed 04/26/19 Page 3 of 3

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WHEREFORE, the parties respectfully request that the Court stay proceedings in this case

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until the resolution of Plaintiff’s Motion to Compel Depositions of Mayor John Lee and Ryann Juden

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and Defendant’s Motion for Protective Order as to the Requested Depositions of Mayor John Lee

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and City Manager Ryann Juden.
DATED this 26th day of April, 2019.
Respectfully submitted,

Respectfully submitted,

MELANIE HILL LAW PLLC

KAMER ZUCKER ABBOTT

/s/ Melanie A. Hill
Melanie A. Hill
#8796
520 S. 7th Street, Suite A
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]

/s/ Kaitlin H. Paxton
R. Todd Creer
#10016
Kaitlin H. Paxton
#13625
3000 West Charleston Boulevard, Suite 3
Las Vegas, Nevada 89102
Tel: [phone]
Fax: [phone]

Attorney for Plaintiff
Pamela Dittmar

Attorneys for Defendant
City of North Las Vegas

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IT IS SO ORDERED.
May 2, 2019
__________________
DATE

UNITED STATES MAGISTRATE JUDGE

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KAMER ZUCKER ABBOTT

Attorneys at Law

3000 West Charleston Boulevard, Suite 3 • Las Vegas, NV 89102 • [phone]

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