Dittmar v. City of North Las Vegas

Filing 99

ORDER Granting 98 Stipulation for Extension of Time Re: 95 Motion for Partial Summary Judgment, 88 Motion for Summary Judgment. Responses due by 6/25/2021. Replies due by 7/16/2021. Signed by Judge Jennifer A. Dorsey on 6/10/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:17-cv-02916-JAD-BNW Document 98 Filed 06/08/21 Page 1 of 3

1
2
3
4
5

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

6
7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

*****

11
12

PAMELA DITTMAR,
Plaintiff,

13
14
15
16
17

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

Case No. 2:17-cv-02916-JAD-BNW
STIPULATION TO EXTEND
DISPOSITIVE MOTION RESPONSE
AND REPLY DEADLINES & ORDER
(Fifth Request)
ECF No. 98

Defendant.

18
19
20
21
22
23
24
25
26
27
28

NOW COMES the Plaintiff, Pamela Dittmar, by and through her attorneys, Melanie A.
Hill and Melanie Hill Law PLLC, and Defendant, City of North Las Vegas, by and through its
attorneys, R. Todd Creer, Kaitlin H. Paxton, and Kamer Zucker Abbott, who hereby stipulate that
the deadlines to file responses to the currently pending dispositive motions be extended from the
current deadline of June 11, 2021 up to and including June 25, 2021 and the deadline to file replies
be extended from the current deadline of July 2, 2021 up to and including July 16, 2021.
This is the fifth request for an extension of the dispositive motion deadline. The first request
was by stipulation to extend the dispositive motion deadline thirty (30) days from the extended
discovery cutoff deadline to complete the remaining two depositions. The second request was by
motion due to Plaintiff’s counsel’s ongoing illness with Covid-19 symptoms. The third request was

–1–
STIPULATION TO EXTEND DISPOSITIVE MOTION RESPONSE AND REPLY DEADLINES

Case 2:17-cv-02916-JAD-BNW Document 98 Filed 06/08/21 Page 2 of 3

1

due to Plaintiff’s counsel’s immediate family member’s emergency hospitalization for nearly one

2

week. The fourth request was due to Plaintiff’s counsel’s significant injuries from two separate

3

accidents. This Stipulation is made at the request of Plaintiff’s counsel for the reasons set forth

4

herein and this is the fifth stipulation for an extension of the response and reply deadlines.

5

In support of this Stipulation and Order, the parties state as follows:

6

1.

The current deadline to file dispositive motions is June 11, 2021. When the parties

7

first entered into a stipulation to extend the dispositive motion deadline, it was to extend the

8

dispositive motion deadline to thirty (30) days from the extended discovery cutoff deadline to

9

complete the remaining two depositions. When the parties next entered into a stipulation to extend

10

the dispositive motion deadline, it was to extend the dispositive motion deadline thirty (30) days

11

due to Plaintiff’s counsel’s ongoing illness with Covid-19 symptoms. The parties then entered into a

12

stipulation for an additional seven (7) days due to Plaintiff’s counsel’s family member’s health

13

emergency. The parties then stipulated to extend the dispositive motion deadline due to Plaintiff’s

14

counsel’s significant injuries from two separate accidents.

15

2.

Counsel for Plaintiff reached out to counsel for Defendant over a weeks ago to

16

inform them that she is still suffering injuries and pain from her accidents and needs to have

17

additional diagnostic tests and pain management and needs additional time from her original

18

estimate to treat and heal. Counsel for Plaintiff further informed counsel for Defendant that she had

19

to put her dog down a few weeks ago. Counsel for Plaintiff continues to be in significant pain from

20

her injuries and has continued to take a significant time off work to treat her injuries, attend physical

21

therapy, and recover necessitating this stipulation to extend the response and reply deadlines.

22

3.

Defendant is sympathetic to Plaintiff’s counsel’s immediate health concerns and

23

recognizes the difficulties with the same. In that regard, Defendant has entered this stipulation so

24

long as it is not prejudiced in preparing its briefs so the parties have also agreed to extend the

25

response and reply deadlines for both parties.

26

4.

The parties have agreed to extend the deadline to file responses to the dispositive

27

motions until June 25, 2021. The parties have further agreed that replies will be due on July 16,

28

2021. No other deadlines are being extended by this stipulation, such as the deadline for discovery
–2–
STIPULATION TO EXTEND DISPOSITIVE MOTION RESPONSE AND REPLY DEADLINES

Case 2:17-cv-02916-JAD-BNW Document 98 Filed 06/08/21 Page 3 of 3

1

and to file a motion to compel written discovery.
5.

2

This stipulation to extend the dispositive motion deadline is brought in good faith,

3

with a showing of good cause, and is not sought for any improper purpose or other purpose of

4

delay, but to allow counsel for the Plaintiff time off from work due to her injuries, allow her time

5

for treatment and physical therapy, seek additional diagnostic treatment and pain therapy, and time

6

to heal from her injuries.

7

necessary to do so prior to filing her response and reply.

This extension will allow counsel for Plaintiff the additional time

8

WHEREFORE, the parties respectfully request by this stipulation that the Court extend

9

the deadline to file responses to the pending dispositive motions from the current deadline of June

10

11, 2021 up to and including June 25, 2021. The parties further request that the Court extend the

11

deadline to file replies to the dispositive motions from the current deadline of July 2, 2021 up to and

12

including July 16, 2021.

13

DATED this 8th day of June, 2021.

14
MELANIE HILL LAW PLLC

15
16
17
18
19
20

By:

KAMER ZUCKER ABBOTT

/s/ Melanie A. Hill
Melanie A. Hill, Esq. (NV Bar No. 8796)
1925 Village Center Circle, Ste. 150
Las Vegas, Nevada 89134
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff Pamela Dittmar

By:

21

/s/ Kaitlin H. Paxton
R. Todd Creer (NV Bar No. 10016)
Kaitlin H. Paxton (NV Bar No. 13625)
3000 West Charleston Blvd., Suite 3
Las Vegas, Nevada 89102
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant City of North
Las Vegas

22
23
24
25
26
27

IT IS SO ORDERED:
____________________________________
JENNIFER A. DORSEY
UNITED STATES DISTRICT JUDGE
6-10-21
Dated: _____________________

28
–3–
STIPULATION TO EXTEND DISPOSITIVE MOTION RESPONSE AND REPLY DEADLINES