Flynn v. State of Nevada ex rel. Nevada Department of Corrections et al

Filing 11

ORDER Granting 9 First Stipulation and Order to Extend Deadline (First Request) to Respond to Defendant's 7 Motion to Dismiss and to File a Discovery Plan. Responses due by 3/13/2023. Discovery Plan/Scheduling Order due by 3/30/2023. Signed by Judge Jennifer A. Dorsey on 1/18/2023. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:22-cv-01753-JAD-NJK Document 11 Filed 01/18/23 Page 1 of 3

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SADMIRA RAMIC, ESQ.
Nevada Bar No.: 15984
CHRISTOPHER M. PETERSON, ESQ.
Nevada Bar No.: 13932
SOPHIA A. ROMERO, ESQ.
Nevada Bar No.: 12446
AMERICAN CIVIL LIBERTIES
UNION OF NEVADA
601 South Rancho Drive, Suite B-11
Las Vegas, NV 89106
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT COURT OF NEVADA

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DAWNYELL FLYNN, an individual,
Case Number:
Plaintiff,

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2:22-cv-01753-JAD-NJK
vs.
STATE OF NEVADA ex rel. NEVADA
DEPARTMENT OF CORRECTIONS, a
public entity of the State of Nevada; DONALD
BURSE, an individual; CHARLES DANIELS,
director, in his official capacity; GABRIELA
NAJERA, warden, in her official capacity;
KARISSA CURRIER, associate warden, in her
official capacity; MONIQUE HUBBARDPICKETT, associate warden, in her official
capacity; and Doe Nevada Department of
Corrections Employees 1 – 10, in their
individual and official capacity,

STIPULATION AND ORDER TO
EXTEND DEADLINE TO RESPOND
TO DEFENDANTS’ MOTION TO
DISMISS AND TO FILE A
DISCOVERY PLAN

Defendant(s).

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ECF Nos. 7, 9

Case 2:22-cv-01753-JAD-NJK Document 11 Filed 01/18/23 Page 2 of 3

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STIPULATION

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(FIRST REQUEST)

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Pursuant to Local Rules IA 6-1, IA 6-2, and 7-1, it is hereby stipulated and agreed by and

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among Defendants, Nevada Department of Corrections (NDOC) and Charles Daniels, and

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Plaintiff, Dawnyell Flynn, as follows:

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1.

Defendants, NDOC and Charles Daniels, removed this action from state court to

federal court on October 19, 2022. See ECF No. 1.

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2.

Defendants filed a Motion to Dismiss on December 30, 2022. See ECF No. 7.

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3.

Defendant Donald Burse has not made an appearance.

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4.

The Court issued an order on December 30, 2022, ordering Plaintiff to respond by

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January 13, 2023.

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5.

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The Court issued an order on December 30, 2022, setting a deadline of January 29,

2023, for a Discovery Plan/Schedule.
6.

On January 12, 2023, counsel for Defendants NDOC and Charles Daniels and

counsel for Plaintiff conferred regarding potential settlement in this matter.

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7.

Settlement negotiations are ongoing.

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8.

The deadline to file an opposition in response to the Motion to Dismiss shall be

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extended 60 days. The new deadline is March 13, 2023.
9.

The deadline to file a Discovery Plan/Schedule shall be extended 60 days. The new

deadline is March 30, 2023.
10.

This is the parties’ first request for an extension of any deadline in this case. The

requested extension is not intended to cause any delay or to prejudice any party.

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Case 2:22-cv-01753-JAD-NJK Document 11 Filed 01/18/23 Page 3 of 3

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AMERICAN CIVIL LIBERTIES UNION OF
NEVADA

OFFICE OF THE ATTORNEY GENERAL

By: /s/ Sadmira Ramic_________________
SADMIRA RAMIC, ESQ.
Nevada Bar No. 15984
601 South Rancho Drive, Suite B-11
Las Vegas, NV 89106
Attorney for Plaintiff

By: /s/ Craig A. Newby
CRAIG A. NEWBY, ESQ.
Nevada Bar No. 8591
555 E. Washington Ave., Ste. 3900 Las
Vegas, Nevada 89101
Attorney for NDOC and Charles Daniels

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ORDER
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IT IS SO ORDERED.

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U.S. DISTRICT COURT JUDGE
1-18-23
DATED: ____________

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