Dittmar v. City of North Las Vegas

Filing 85

ORDER granting 84 Stipulation to Extend Deadlines; Motions due by 3/1/2021. Proposed Joint Pretrial Order due by 3/31/2021. Signed by Magistrate Judge Brenda Weksler on 1/11/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:17-cv-02916-JAD-BNW Document 84 Filed 01/08/21 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
PAMELA DITTMAR,

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Plaintiff,
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vs.
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CITY OF NORTH LAS VEGAS, a municipal )
corporation,
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Defendant.
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______________________________________ )

Case No. 2:17-cv-02916-JAD-BNW
STIPULATION AND REQUEST FOR
EXTENSION OF DISPOSITIVE
MOTION AND JOINT PRETRIAL
ORDER DEADLINES
(First Request)

Pursuant to Local Rule IA 6-1 and Local Rule 26-3, the parties, by and through their respective
counsel of record, stipulate and request that the Court grant an extension of time for the remaining
deadlines, including dispositive motions, to correspond with today’s Order for a three-week extension
for limited discovery. In support of this Stipulation and Request, the parties state as follows:
1. Discovery was scheduled to conclude on December 31, 2020 (ECF No. 71).
2. Defendant filed an Emergency Motion for Protective Order regarding two depositions on
December 28, 2020 (ECF No. 72). In Plaintiff’s Response filed on December 31, 2020, she
requested the discovery deadline be extended for limited purposes (ECF No. 77).

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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 84 Filed 01/08/21 Page 2 of 3

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3. On January 8, 2021, the Court ordered a limited, three-week extension to the discovery

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deadline from the date of the Order to conduct the two depositions (ECF No. 83). This

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creates a new discovery deadline of January 29, 2021.

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4. Transcripts of depositions typically take two (2) weeks to prepare. Then, the deponents will
each have 30 days to review and make any necessary changes to their deposition transcripts.
5. Based on this time frame, the deposition review/correction process will likely not be
completed before the current February 1, 2021 dispositive motion deadline.

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6. Since the depositions taken by the parties may be important for briefing any dispositive

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motions that are filed, the parties are seeking an extension of time of the dispositive motion

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deadline to allow for the completion of the deposition review process by both parties. The

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parties further seek a corresponding extension for the Joint Pretrial Order. The new deadlines

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will be as follows:

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Dispositive Motion Deadline: Monday, March 1, 2021

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•

Joint Pretrial Order: Pursuant to LR 26(1)(e)(5) the Joint Pretrial Order shall be filed

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with this Court no later than thirty (30) days after the date set for filing dispositive

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motions, which shall be by Wednesday, March 31, 2021, unless dispositive motions

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are filed, in which case the date for filing the Joint Pretrial Order shall be suspended

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until thirty (30) days after the decision on the dispositive motions or further order of

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this Court. The disclosures required by Fed. R. Civ. P. 26(a)(3) and any objections

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shall be included in the final pretrial order.

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7. 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 complete

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dispositive motions in this case following the conclusion of the deposition review process as

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set forth above.

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 84 Filed 01/08/21 Page 3 of 3

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8. This is the first request for an extension of time of the dispositive motion and Joint Pretrial

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Order deadlines in this matter. Pursuant to LR 26-3, this Request has been made at least 21

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days prior to the current dispositive motion deadline.

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WHEREFORE, the parties respectfully request that the Court extend the dispositive motion deadline

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from February 1, 2021 to March 1, 2021 and the Joint Pretrial Order deadline from March 3, 2021

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to March 31, 2021 in this matter.
DATED this 8th day of January, 2021.

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Respectfully submitted,

Respectfully submitted,

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MELANIE HILL LAW PLLC

KAMER ZUCKER ABBOTT

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/s/ Melanie A. Hill
Melanie A. Hill
#8796
th
520 S. 7 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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ORDER
IT IS SO ORDERED.
IT IS SO ORDERED

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DATED: 4:29 pm, January 11, 2021

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DATE

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UNITED STATES MAGISTRATE JUDGE
BRENDA WEKSLER
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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