Miller v. Nye County et al

Filing 47

ORDER Granting 46 Stipulation for extension of Time. Motions due by 3/2/2021. Signed by Magistrate Judge Daniel J. Albregts on 2/16/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:19-cv-00601-JAD-DJA Document 46 Filed 02/12/21 Page 1 of 3
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02/16/21

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Margaret A. McLetchie, Nevada Bar No. 10931
Alina M. Shell, Nevada Bar No. 11711
MCLETCHIE LAW
701 East Bridger Ave., Suite 520
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Jennifer L. Braster, Nevada Bar No. 9982
Andrew J. Sharples, Nevada Bar No. 12866
NAYLOR & BRASTER
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff Gary Miller

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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GARY MILLER, an individual,
vs.

Plaintiff,

NYE COUNTY, Nevada, a political
subdivision of the State of Nevada and doing
business as the Nye County Sheriff’s Office
and Nye County Animal Control; and
DEPUTY JOHN TOLLE, individually and
in his official capacity as a Nye County
Police Officer;

Case. No.: 2:19-cv-00601-JAD-DJA
STIPULATION AND ORDER TO
EXTEND DISPOSITIVE MOTION
DEADLINE
(SECOND REQUEST)
Complaint filed: April 9, 2019
FAC filed: September 25, 2019

Defendants.

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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

Pursuant to LR IA 6-1, Plaintiff, Gary Miller and Defendants, Nye County and Deputy
John Tolle, by and through their respective counsel of record, submit this Stipulation and Order to
Extend Dispositive Motion Deadline. The parties respectfully request the dispositive motion
deadline be extended by two (2) weeks.

Case 2:19-cv-00601-JAD-DJA Document 46 Filed 02/12/21 Page 2 of 3
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02/16/21

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Currently the dispositive motion deadline is February 16, 2021. (ECF No. 45). The parties

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respectfully request the dispositive motion deadline be extended until March 2, 2021. Similarly,

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the parties hereby request that the last day to file a Joint Pretrial Order shall be extended for two

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(2) weeks or until April 1, 2021. In the event dispositive motions are filed, the date for filing the

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Joint Pretrial Order shall be suspended until thirty (30) days after decision on the dispositive

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motions or upon further Order by the Court extending the time period in which to file the Joint

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Pretrial Order.

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The parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested
extension.

Due to extenuating circumstances, including several court-ordered deadlines,

Plaintiff’s counsel respectfully requested a 2-week extension, and Defendant’s counsel agreed.
Further, the parties believe that dispositive motions may resolve issues related in the case,
such as the same will not be required to proceed to a jury and will conserve judicial resources.

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This extension request is made in good faith, jointly by the parties, and not for the purposes

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of delay. Trial in this matter has not yet been set. Moreover, since this request is a joint request,

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neither party will be prejudiced.

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This Request for an extension of time is not sought for any improper purpose or other

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purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient

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time to prepare dispositive motions in this case and adequately prepare their respective cases for

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trial to the extent the dispositive motions do not resolve all of the claims.

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This is the second request for extension of the dispositive motion deadline in this matter.

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The parties respectfully submit that the reasons set forth above constitute compelling reasons for

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the extension.

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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

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Case 2:19-cv-00601-JAD-DJA Document 46 Filed 02/12/21 Page 3 of 3
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02/16/21

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WHEREFORE, the parties respectfully request that this Court extend the deadline to file

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dispositive motions in the above-captioned case two (2) weeks, up to and including March 2, 2021

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and the other dates as outlined in accordance with the table above.

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NAYLOR & BRASTER

MARQUIS AURBACH COFFING

By: /s/ Jennifer L. Braster
Jennifer L. Braster, NV Bar No. 9982
Andrew J. Sharples, NV Bar No. 12866
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145

By: /s/ James A. Beckstrom
Craig R. Anderson, NV Bar No. 6882
James A. Beckstrom, NV Bar No. 14032
10001 Park Run Drive
Las Vegas, Nevada 89145

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Margaret A. McLetchie, NV Bar No.10931
Alina M. Shell, NV Bar No. 11711
MCLETCHIE LAW
701 East Bridger Avenue, Suite 520
Las Vegas, NV 89101
Attorneys for Plaintiff Gary Miller

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Attorneys for Defendants Nye County and
Deputy John Tolle

ORDER
IT IS SO ORDERED.

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DATED this 16th day of February, 2021.
Dated this ___ day of February 2021.

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____________________________________

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UNITED STATES MAGISTRATE JUDGE

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NAYLOR & BRASTER
ATTORNEYS AT LAW
1050 Indigo Drive, Suite 200
Las Vegas, NV 89145
[phone]

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