Lechner v. LVMPD et al

Filing 174

ORDER Granting 172 Stipulation for Extension of Time. Proposed Joint Pretrial Order due by 4/5/2024. Signed by Magistrate Judge Maximiliano D. Couvillier, III on 3/26/2024. (Copies have been distributed pursuant to the NEF - AMMi)

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10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 1 Marquis Aurbach Nick D. Crosby, Esq. 2 Nevada Bar No. 8996 Jackie V. Nichols, Esq. 3 Nevada Bar No. 14246 10001 Park Run Drive 4 Las Vegas, Nevada 89145 Telephone: (702) 382-0711 5 Facsimile: (702) 382-5816 ncrosby@maclaw.com 6 jnichols@maclaw.com Attorneys for Defendants LVMPD, Christopher R. O’Connell, 7 Clint W. Owensby, Jonathan M. Riddle, Christopher J. Kopf, Dillon A. Wedewer and Andre A. McFarland 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 GERALD R. LECHNER, an individual, Case Number: 11 2:19-cv-00638-RFB-MDC Plaintiff, 12 vs. STIPULATION AND ORDER TO 13 EXTEND JOINT PRETRIAL ORDER LAS VEGAS METROPOLITAN POLICE DEADLINE 14 DEPARTMENT, CHRISTOPHER R. O’CONNELL, in his individual and official (SEVENTH REQUEST) 15 capacities, & CLINT W. OWENSBY, in his individual and official capacities, & 16 JONATHAN M. RIDDLE, in his individual and official capacities, & CHRISTOPHER J. 17 KOPF, in his individual and official capacities, & DILLON A. WEDEWER, in his 18 individual and official capacities, & ANDRE A. MCFARLAND, in his individual and 19 official capacities, 20 21 Defendants. The Parties, by and through their undersigned counsel of record, and hereby agree 22 and jointly stipulate that the Joint Pretrial Order [ECF No. 171], currently due on Friday, 23 March 22, 2024, be extended to and including Friday, April 5, 2024. 24 Plaintiff is responsible for initiating and preparing the Joint Pretrial Order. Due to 25 the fact that Plaintiff is not signed up for electronic service, he did not immediately receive 26 notice of the Court’s summary judgment ruling. The parties have had communications and 27 Plaintiff recently (on January 18, 2024) provided a draft of the Joint Pretrial Order to Page 1 of 4 MAC:14687-128 5422029_1 3/22/2024 1:07 PM 1 Defendants’ counsel. Counsel for Defendants has several competing deadlines and provided 2 comments and redline changes to the proposed Joint Pretrial Order on February 19, 2024 to 3 Plaintiff. The parties are continuing communications, including phone calls to reach a 4 resolution regarding the Joint Pretrial Order. 5 Furthermore, counsel for LVMPD and Officer Salazar was in a three-week trial in 6 the Eighth Judicial District Court, Clark County Nevada, before the honorable Judge Jacob 7 Reynolds from February 20, 204 to March 8, 2024 in the James M. Herndon v. City Of 8 Henderson, et al. matter (A-21-842739-C). This hindered the parties ability to effectively 9 communicate about the Joint Pretrial Order. The parties are working diligently in 10 addressing the joint pre-trial order and continue to work in good faith with one another. 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 As such, the Parties respectfully request a 14-day extension of the deadline to submit 12 the Joint Pretrial Order. This request for extension is made in good faith and necessary to 13 provide additional time for preparation of the Joint Pretrial Order and not for the purposes of 14 delay. 15 . . . 16 . . . 17 . . . 18 . . . 19 . . . 20 . . . 21 . . . 22 . . . 23 . . . 24 . . . 25 . . . 26 . . . 27 . . . Page 2 of 4 MAC:14687-128 5422029_1 3/22/2024 1:07 PM 1 WHEREFORE, the parties respectfully request that the Joint Pretrial Order be 2 extended to and including Friday, April 5, 2024. 3 DATED this 22nd day of March, 2024 DATED this 22nd day of March, 2024 4 MARQUIS AURBACH 5 By: 6 7 /s/ Gerald R. Lechner Gerald R. Lechner 246 Highgate Street Henderson, Nevada 89074 Plaintiff Pro Per By: 8 9 10 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 /s/ Jackie V. Nichols Nick D. Crosby, Esq. Nevada Bar No. 8996 Jackie V. Nichols, Esq. Nevada Bar No. 14246 10001 Park Run Drive Las Vegas, Nevada 89145 Attorneys for Defendants LVMPD, Christopher R. O’Connell, Clint W. Owensby, Jonathan M. Riddle, Christopher J. Kopf, Dillon A. Wedewer and Andre A. McFarland ORDER 12 13 The above Stipulation is hereby GRANTED. 14 IT IS SO ORDERED. 15 16 17 ______________________________________ Maximiliano D. Couvillier III UNITED STATES MAGISTRATE JUDGE DATED: March 26, 2024 18 19 20 21 22 23 24 25 26 27 Page 3 of 4 MAC:14687-128 5422029_1 3/22/2024 1:07 PM 1 2 CERTIFICATE OF SERVICE I hereby certify that I electronically filed the foregoing STIPULATION AND 3 ORDER TO EXTEND JOINT PRETRIAL ORDER DEADLINE (SEVENTH 4 REQUEST) with the Clerk of the Court for the United States District Court by using the 5 court’s CM/ECF system on the 22nd day of March, 2024. 6 I further certify that all participants in the case are registered CM/ECF users 7 and that service will be accomplished by the CM/ECF system. 8 I further certify that some of the participants in the case are not registered 9 CM/ECF users. I have mailed the foregoing document by First-Class Mail, postage prepaid, 10 or have dispatched it to a third party commercial carrier for delivery within 3 calendar days 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH 11 to the following non-CM/ECF participants: 12 13 Gerald R. Lechner 246 Highgate Street Henderson, Nevada 89074 Plaintiff Pro Per 14 15 16 /s/ Krista Busch An employee of Marquis Aurbach 17 18 19 20 21 22 23 24 25 26 27 Page 4 of 4 MAC:14687-128 5422029_1 3/22/2024 1:07 PM

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