Smith v. State of Nevada ex rel
Filing
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ORDER Granting 39 Stipulation for Extension of Time re 27 Scheduling Order (Second Request). Motions due by 3/15/2019. Signed by Magistrate Judge George Foley, Jr on 2/21/2019. (Copies have been distributed pursuant to the NEF - MR)
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AARON D. FORD
Attorney General
KATLYN M. BRADY (Bar. No. 14173)
Deputy Attorney General
DOMINIKA J. BATTEN (Bar. No. 12258)
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave. Ste. 3900
Las Vegas, NV 89101
(702) 486-0661 (phone)
(702) 486-3773 (fax)
katlynbrady@ag.nv.gov
dbatten@ag.nv.gov
Attorneys for State of Nevada
ex rel. its Department of Transportation
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UNITED STATES DISTR ICT COURT
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DISTRICT OF NEVADA
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MONIKA SMITH,
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Plaintiff,
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Case No. 2:18-cv-00640-JAD-GWF
vs.
STATE OF NEVADA ex rel its DEPARTMENT
OF TRANSPORTATION,
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STIPULATION AND ORDER
EXTENDING DEADLINE TO FILE
DISPOSITIVE MOTIONS
(SECOND REQUEST)
Defendant.
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Pursuant to Local Rules IA 6-1, IA 6-2, and 26-4, Plaintiff Monika Smith and Defendant State
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of Nevada, ex rel. its Department of Transportation (NDOT) by and through their respective attorneys,
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hereby stipulate and agree to extend the dispositive motions deadline currently set for Thursday,
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February 28, 2019, to March 15, 2019. This is the parties’ second stipulation for extension of time
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with respect to the dispositive motions deadline and also the second stipulation for extension of time
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overall in this case (the original dispositive motions deadline was Tuesday February 12, 2019, but was
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extended to Thursday, February 28, 2019, after Plaintiff’s deposition was rescheduled from January
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10, 2019, but was moved to January 30, 2019, pursuant to NDOT’s request).
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This request for extension is not brought about to cause undue delay. Good cause exists for the
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extension due to primary defense counsel’s current litigation and administrative schedule. Primary
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counsel for NDOT handles all of NDOT’s personnel-related litigation, administrative and day-to-day
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counsel statewide and is diligently working on the summary judgment motion, but is in need of
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additional time to properly research and analyze the issues in this case and finalize the summary
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judgment motion. Additionally, secondary defense counsel is assisting in drafting the summary
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judgment motion, but is scheduled out of the office February 22 until February 26, 2019. The fifteen-
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day extension of dispositive motion deadline is to allow sufficient time for drafting the dispositive
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motions.
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RESPECTFULLY SUBMITTED this 20th day of February 2019.
AARON D. FORD
Attorney General
LIZADA LAW FIRM
By: /s/ Dominika J. Batten
DOMINIKA J. BATTEN (Bar. No. 12258)
Deputy Attorney General
Attorneys for Defendant
/s/ _Angela J. Lizada_________________
ANGELA J. LIZADA (Bar No. 11637)
Attorney for Plaintiff
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ORDER
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IT IS SO ORDERED.
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UNITED STATES MAGISTRATE JUDGE
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2/21/2019
DATED: ____________________________
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