Villarreal v. Correa et al

Filing 42

ORDER granting 41 Stipulation Re: 38 Motion for Summary Judgment. Responses due by 6/12/2024. Replies due by 6/26/2024. Signed by Judge Gloria M. Navarro on 5/8/2024. (Copies have been distributed pursuant to the NEF - HAM)

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LAW OFFICE OF JORDAN MARSH LLC
Jordan Marsh
5 Revere Drive Suite 200
Northbrook, IL 60062
[phone]|Fax: [phone]
[e-mail]
IL Bar #6216489
THE LAW OFFICE OF HAYES & WELSH
Martin L. Welsh, Esq
199 N. Arroyo Grande Blvd., Suite 200
Henderson, Nevada 89074
[phone] | Fax: [phone]
[e-mail]
NV Bar #8720

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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AMY VILLARREAL,
Plaintiff,

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JOINT STIPULATION TO MODIFY
THE BRIEFING SCHEDULE

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vs.

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North Las Vegas Police Officer JORGE
CORREA, CITY OF NORTH LAS
VEGAS, A Political Subdivision of the
State of Nevada,

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Case No.: 2:22-cv-00815-GMN-DJA

Defendants.
JOINT STIPULATION TO MODIFY THE BRIEFING SCHEDULE

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff, AMY

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VILLAREAL (“Plaintiff”), and Defendants CITY OF NORTH LAS VEGAS and JORGE

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CORREA (“Defendants”) (collectively hereinafter “the Parties”), by and through their

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counsel of record, that the current deadline for Plaintiff’s Response to Defendants’ Motion
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for Summary Judgement of May 22, 2024, be continued to June 12, 2024, and the

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deadline to file any Reply in support of the Motion for Summary Judgement continued to

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June 26, 2024.

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Since Plaintiff’s counsel is a sole practitioner and has two trials scheduled in May, the
requested extension will afford the Parties sufficient time to present their arguments to
the Court.

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I.

PROPOSED EXTENDED DEADLINES

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The parties respectfully request this Court enter and order as follows:

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A. Motion for Summary Judgment Briefing Schedule

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The Plaintiff shall file her response to the Motion on or before June 12, 2024; and any

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reply in support of the motion be filed on or before June 26, 2024.

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This request for an extension is made in good faith and joined by all the parties in this

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case. Trial is not yet set in this matter. Accordingly, this extension will not delay this case.

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Moreover, since this request is a joint request, neither party will be prejudiced.
IT IS SO STIPULATED

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Dated: May 9, 2024.

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/s/ Jordan Marsh

/s/ Noel Eidsmore

LAW OFFICE OF JORDAN MARSH
LLC
5 Revere Drive, Suite 200
Northbrook, IL 60062

NORTH LAS VEGAS CITY
ATTORNEY
Micaela Rustia Moore, Esq.
Nev. Bar No. 9676
City Attorney
Noel E. Eidsmore, Esq.
Nev. Bar No. 7688
Chief Deputy City Attorney
Madison Zornes-Vela
Nev. Bar No. 13626
Deputy City Attorney
2250 Las Vegas Blvd. North, Suite 810
North Las Vegas, Nevada 89030
Attorneys for the Defendants

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And
Martin L. Welsh, Esq
THE LAW OFFICE OF HAYES &
WELSH
199 N. Arroyo Grande Blvd., Suite 200
Henderson, Nevada 89074
Attorneys for the Plaintiff

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