McIntosh v. City of North Las Vegas et al

Filing 69

ORDER granting ECF No. 68 Stipulation for Extension of Time. Proposed Joint Pretrial Order due by 12/1/2023. Signed by Magistrate Judge Elayna J. Youchah on 11/13/2023. (Copies have been distributed pursuant to the NEF - GA)

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1 2 3 4 JAMES P. KEMP, ESQ. Nevada Bar No.: 6375 KEMP & KEMP 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 702-258-1183 ph./702-258-6983 fax Attorneys for Plaintiff Donavan McIntosh 5 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 DONAVAN McINTOSH, 9 10 11 12 13 14 15 16 Case No. 2:21-cv-01505-APG-EJY Plaintiff, vs. STIPULATION AND ORDER TO EXTEND DEADLINE FOR JOINT PRETRIAL ORDER CITY OF NORTH LAS VEGAS, a Municipal Corporation and political subdivision of the State of Nevada; PAMELA OJEDA in her official and/or individual capacities; CLINTON [SECOND REQUEST] RYAN in his official and/or individual capacities; ALEJANDRO RODRIGUEZ in his official and/or individual capacities; DOES I-X, Defendants. 17 18 19 Plaintiff Donavan McIntosh (“Plaintiff’) and Defendants City of North Las Vegas 20 (“CNLV”), Pamela Ojeda (“Chief Ojeda”), Clinton Ryan (“Asst. Chief Ryan”), and Alejandro 21 Rodriguez (“Lt. Rodriguez,” and collectively, “Defendants”), by and through their undersigned 22 counsel, hereby file this Stipulation and Order to Extend Deadline for Joint Pre-Trial Order (First 23 Request). This is the second request to extend this deadline. The parties stipulate that the 24 current deadline of November 13, 2023 (November 10 was a holiday) should be extended to 25 Friday, December 1, 2023 and informs the court as follows: 26 27 1. The current deadline was established by the first request of the parties approved by the court on September 25, 2023. 28 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2. During the interim period CNLV litigated a Motion to Strike the Amended Complaint and the court denied that motion on October 2, 2023. [ECF No. 66] 3. Thereafter, CNLV filed an Answer to the Amended Complaint on October 20, 2023. [ECF No. 67] 4. During the period of October 26 through November 3 Plaintiff’s counsel was attending a 40 hour Mediation Certificate CLE training program through Quinnipiac University School of Law and traveled to Connecticut for the in-class portion of the training. Plaintiff’s counsel was in Connecticut from November 1 through November 6 because after the training program ended Plaintiff’s counsel’s son came to Connecticut and Plaintiff’s counsel attended the law school’s open house with his son on November 4 and a tour and discussion of admissions and financial aid with law school staff as Plaintiff’s son is applying to law schools this fall. 5. Further, in the interim Plaintiff’s counsel was out of town for the Nevada Justice Association CLE convention in San Diego from October 4-6, 2023. 6. Further Plaintiff’s counsel had out of state depositions in Orange County, California on October 9, 2023. 7. Further Plaintiff’s counsel has had multiple mediations/settlement conferences, other depositions, multiple administrative workers’ compensation and unemployment hearings, and briefing due in an arbitration case. 8. Plaintiff’s counsel is focusing on the Joint Pre-Trial Order this week and will have a first draft of the document to Defense counsel by no later than close of business on November 14, 2023. Given the upcoming Thanksgiving Holiday (Plaintiff’s counsel is traveling out of the country beginning November 17, 2023) the parties are requesting the new deadline be the Friday after the holiday week, which is December 1, 2023 as this should be sufficient time to finalize the Joint Pre-Trial Order. 9. The requested extension is sought in good faith and not for purposes of undue delay. 27 28 2 1 2 3 IT IS STIPULATED AND AGREED that the parties shall file the Joint Pre-Trial Order no later than December 1, 2023. IT IS SO STIPULATED. 4 5 Dated this 13th day of November 2023 6 KEMP & KEMP HONE LAW /s/ James P. Kemp James P. Kemp, NV Bar No. 6375 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 /s/ Jill Garcia Jill Garcia, NV Bar No. 7805 701 N. Green Valley Parkway, Suite 200 Henderson, NV 89074 Attorney for Plaintiff Attorneys for Defendants 7 8 9 10 11 12 13 ORDER 14 15 IT IS SO ORDERED. 16 17 _____________________________________ UNITED STATES MAGISTRATE JUDGE 18 19 Dated: 20 21 22 23 24 25 26 27 28 3 November 13, 2023 .

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