Dittmar v. City of North Las Vegas

Filing 61

ORDER Granting 60 Stipulation to Stay Proceedings for Sixty Days Signed by Magistrate Judge Brenda Weksler on 4/2/2020. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:17-cv-02916-JAD-BNW Document 60 Filed 03/26/20 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-BNW
)
Plaintiff,
)
JOINT STIPULATION AND ORDER
TO STAY PROCEEDINGS FOR
)
SIXTY DAYS
vs.
)
)
(Second Request)
CITY OF NORTH LAS VEGAS, a municipal )
corporation,
)
)
Defendant.
)
)
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 for sixty (60) days, through and

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including May 26, 2020, in light of orders from the state to limit in-person interactions during the

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

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PAMELA DITTMAR,

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1.

Currently, the discovery deadline is set for May 18, 2020.

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2.

The parties intend to take at least four depositions before discovery closes, which

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would require in-person interactions that should be avoided at this time due to the CoVID-19

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pandemic and the declaration of a national emergency and Nevada state of emergency. Even video

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conferencing depositions would require at least a videographer in the same room as both the deposing

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-BNW Document 60 Filed 03/26/20 Page 2 of 3

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attorney and the witness being deposed. Further, at least some of the witnesses have been subject to

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state closures and are expected to stay home at this time and one of the depositions is of John Lee,

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the Mayor of the City of North Las Vegas and another one of the depositions is of Ryann Juden, the

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City Manager for the City of North Las Vegas, both of whom are handling issues related to the

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pandemic on a daily basis.

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3.

The remaining depositions have not been conducted yet in this case because some

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document-based discovery still needed to be completed prior to the taking of the depositions that was

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further delayed by issues requesting the documents from third parties.

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4.

The parties have stayed discovery once pending the outcome of a hearing regarding

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compelling the depositions of Mayor John Lee and City Manager Ryann Juden. Discovery has also

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been extended previously, so rather than ask for additional extensions without knowing when the

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pandemic will be suppressed, allowing for in-person depositions again, and in an effort to conserve

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both the parties’ and the court’s limited time and resources due to the partial shutdown, the parties

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seek to stay all proceedings and related deadlines for at least sixty (60) days.

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5.

In the event the pandemic has been sufficiently suppressed by May 19, 2020, the

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parties agree to submit a Joint Status Report within seven (7) days requesting a lifting of the stay of

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discovery and outlining updated deadlines.

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6.

In the event the pandemic has not been sufficiently suppressed by May 26, 2020, the

parties will further confer about requesting an extension of the stay.

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7.

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’ and court’s respective resources and

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efficiently yet responsibly conduct discovery.

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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-BNW Document 60 Filed 03/26/20 Page 3 of 3

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WHEREFORE, the parties respectfully request that the Court stay proceedings in this case
for the next sixty (60) days.
DATED this 26th day of March, 2020.
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.
4/2/2020
__________________
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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