Morgan v. State of Nevada, ex rel., et al

Filing 79

ORDER Granting 78 Stipulation for Extension of Time for Plaintiff to Respond to Defendants' Motion for Summary Judgment. Responses due by 4/4/2025. Replies due by 4/18/2025. Signed by Judge Kent J. Dawson on 3/4/2025. (Copies have been distributed pursuant to the NEF - JG)

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E. BRENT BRYSON, ESQ.
Nevada Bar No. 004933
E. BRENT BRYSON, LTD.
375 E. Warm Springs Rd., Ste. 104
Las Vegas, NV 89119
[phone] Telephone
[phone] Facsimile
[e-mail]
Attorney for Plaintiff,
Joseph Morgan

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOSEPH MORGAN, an Individual

Case No.: 2:19-cv-02239-KJD-DJA

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Plaintiff,
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vs.
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STATE OF NEVADA, ex rel. its
DEPARTMENT OF BUSINESS AND
INDUSTRY, STATE OF NEVADA, ex rel. its
TAXICAB AUTHORITY; BRUCE
BRESLOW, in his individual capacity; TERRY
REYNOLDS, in his individual capacity;
SCOTT WHITTEMORE, in his individual
capacity; RUBEN AQUINO, in his individual
capacity; GENEVIEVE HUDSON, in her
individual capacity; RONALD GROGAN, in
his individual capacity;
CHARLES HARVEY, in his individual
capacity; ANTOINE “CHRIS” RIVERS, in his
individual capacity; CJ MANTHE, in her
individual capacity; DOES I through X
inclusive; and ROES XI through XX, inclusive,

STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR PLAINTIFF
TO RESPOND TO DEFENDANTS’
MOTION FOR SUMMARY JUDGMENT
[ECF NO. 76]
[FIRST REQUEST]

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Defendants.
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Pursuant to LR IA 6-1, LR 7-2 and LR 26-3, Plaintiff JOSEPH MORGAN (“Plaintiff”), by

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and through his counsel of record, E. Brent Bryson, Esq. of the law offices of E. Brent Bryson, Ltd.,
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and Defendants STATE OF NEVADA, ex rel. its DEPARTMENT OF BUSINESS AND
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INDUSTRY, STATE OF NEVADA, ex rel. its TAXICAB AUTHORITY (together “the Agency

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Defendants”) and BRUCE BRESLOW, TERRY REYNOLDS, SCOTT WHITTEMORE, RUBEN

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AQUINO, GENEVIEVE HUDSON, RONALD GROGAN, CHARLES HARVEY, ANTOINE

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“CHRIS” RIVERS AND C. J. MANTHE (each an “Individual Defendant” and collectively the

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“Individual Defendants” and together with the Agency Defendants “the Defendants”), by and

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through their attorneys of record, AARON D. FORD, Attorney General for the State of Nevada, and

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BRUCE C. YOUNG, Senior Deputy Attorney General:

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HEREBY STIPULATE AND REQUEST that this Court extend the Wednesday, March 5,

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2025 deadline for Plaintiff to respond in opposition to Defendants’ motion for summary judgment

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filed on Monday, February 12, 2025 [ECF No. 76] by 30 days, or up to and including Friday, April

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4, 2025, and that Defendants’ Reply in support of Defendants’ motion for summary judgment, if any,

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would be due 14 days after Plaintiff files his response, or by Friday, April 18, 2025. This is the

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parties’ first request to modify the motion for summary judgment briefing schedule.

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In support of this stipulation and request, the parties state that good cause exists as follows:
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That Plaintiff’s attorney is currently preparing for two district court trials set to commence in

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mid-March, 2025. The first trial will commence on March 17, 2025 in case styled, C-24-

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383125-1, The State of Nevada v. Square One Behavioral Health, LLC, and is expected to

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last about a week. The second trial will commence on March 24, 2025 in case styled, A-22-

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850074-C, Jay Francis, et al v. David Garretson, et al, and is expected to last about a week.

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Both trials require extensive trial preparation.

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2.

Because of the large volume of discovery, including 9 depositions, Plaintiff’s response in

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opposition will be complicated and time-consuming - an effort that would be hindered if

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Plaintiff’s counsel had to simultaneously prepare for two district court trials.

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That as a result, the parties met and conferred telephonically on February 26, 2025 and

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mutually agreed to extend the March 5, 2025 due date of Plaintiff’s response in opposition by

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30 days, or up to and including Friday, April 4, 2025. This modification to the motion for

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summary judgment briefing schedule will allow Plaintiff’s counsel the time needed to

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adequately prepare and respond to Defendants’ motion for summary judgment [ECF No. 76].
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That Defendants’ Reply in support of its motion for summary judgment [ECF No. 76] would

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therefore also be extended 30 days, or from Wednesday, March 19, 2025, the current due

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date, up to and including Friday, April 18, 2025.

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That based on good cause set forth above, the parties submit the following proposed

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modifications to the motion for summary judgment briefing schedule:

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Scheduled Event

Current Deadline

Proposed Deadline

Plaintiff’s Response in
Opposition to Motion for
Summary Judgment [ECF
No. 76]

Wednesday, March 5, 2025

Friday, April 4, 2025

Defendants’ Reply in
Support of Motion for
Summary Judgment [ECF
No. 76], if any.

Wednesday, March 19, 2025

Friday, April 18, 2025

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

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purposes of delay. The parties have worked diligently at complying with the deadlines that can be

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met, but good cause exists to extend the current summary judgment briefing schedule.

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