Garcia v. Corner Investment Company, LLC d/b/a The Cromwell Las Vegas et al

Filing 54

ORDER Granting 53 Stipulation for Extension of Time. Motions due by 11/27/2023. Signed by Magistrate Judge Cam Ferenbach on 11/13/2023. (Copies have been distributed pursuant to the NEF - RGDG)

1 Marquis Aurbach
Craig R. Anderson, Esq.
2 Nevada Bar No. 6882
Jackie V. Nichols, Esq.
3 Nevada Bar No. 14246
10001 Park Run Drive
4 Las Vegas, Nevada 89145
Telephone: [phone]
5 Facsimile: [phone]
[e-mail]
6 [e-mail]
Attorneys for Defendants Las Vegas Metropolitan
7
Police Department, Jacob Adams and Miguel Jahuey
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UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10 Fernando Garcia,

10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

MARQUIS AURBACH

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Case Number:
2:22-cv-01960-MMD-VCF
Plaintiff,

vs.

13 Corner Investment Company, LLC d/b/a The
Cromwell Las Vegas, Jacob Adams, Miguel
14 Jahuey, the Las Vegas Metropolitan Police
Department, a municipality, and Does I-XX,
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Defendants.
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STIPULATION AND ORDER TO
EXTEND DISPOSITIVE MOTION
DEADLINE
(FIRST REQUEST)

The Parties, Plaintiff Fernando Garcia (“Plaintiff”), by and through their attorneys of

18 record, Robert A. Nersesian, Esq. and Thea Marie Sankiewicz, Esq., with the law firm of
19 Nersesian & Sankiewicz and Defendants, Las Vegas Metropolitan Police Department
20 (“LVMPD”), Officer Jacob Adams (“Adams”) and Officer Miguel Jahuey (“Jahuey”)
21 (collectively “LVMPD Defendants”), by and through their attorneys of record, Craig R.
22 Anderson, Esq. and Jackie V. Nichols, Esq., with the law firm of Marquis Aurbach, and
23 hereby agree and jointly stipulate the following:
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1.

This request for an extension of time to file dispositive motions is not sought

25 for an improper purpose or other purpose of delay. The parties are requesting a 14-day
26 extension of the dispositive motion deadline. Additionally, counsel for LVMPD Defendants
27 has had several depositions in the Kelly Patterson v. Las Vegas Metropolitan Police
28 Department, et al, United States District Court, District of Nevada, Case No. 2:23-cv-00539Page 1 of 3
MAC:14687-343 5285875_1 11/13/2023 1:19 PM

1 RFB-DJA and B.H., et al. v. CCSD, et al., United States District Court, District of Nevada,
2 Case No. 2:23-cv-00564-JCM-DJA, throughout the month of November. This is the first
3 request for extension of time in this matter. The parties respectfully submit that the reasons
4 set forth above constitute compelling reasons for the modest extension.
5

2.

The Parties further agree, the dispositive motion deadline currently set for

6 November 13, 2023 shall be extended to Monday, November 27, 2023.
7

3.

WHEREFORE, the parties respectfully request that the Dispositive Motion

8 be extended to and including Monday, November 27, 2023.
9

4.

10001 Park Run Drive
Las Vegas, Nevada 89145
[phone] FAX: [phone]

MARQUIS AURBACH

10

This Stipulation is being entered in good faith and not for purposes of delay.

IT IS SO STIPULATED.

11 Dated this 13th day of November, 2023.

Dated this 13th day of November, 2023.

12 NERSESIAN & SANKIEWICZ

MARQUIS AURBACH

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By:

/s/ Robert A. Nersesian
Robert A. Nersesian, Esq.
Nevada Bar No. 2762
Thea Marie Sankiewicz, Esq.
Nevada Bar No. 2788
528 S. Eighth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff Fernando Garcia

By:

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19
ORDER

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/s/ Jackie V. Nichols
Craig R. Anderson, Esq.
Nevada Bar No. 6882
Jackie V. Nichols, Esq.
Nevada Bar No. 14246
10001 Park Run Drive
Las Vegas, Nevada 89145
Attorneys for Defendants Las Vegas
Metropolitan Police Department, Jacob
Adams and Miguel Jahuey

The above Stipulation is hereby GRANTED.
IT IS SO ORDERED.
___________________________________
United States District Court Magistrate Judge
11-13-2023
DATED: _________________________

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MAC:14687-343 5285875_1 11/13/2023 1:19 PM

1
2

CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing STIPULATION AND

3 ORDER TO EXTEND DISPOSITIVE MOTION DEADLINE (FIRST REQUEST)
4 with the Clerk of the Court for the United States District Court by using the court’s CM/ECF
5 system on the 13th day of November, 2023.
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
[phone] FAX: [phone]

MARQUIS AURBACH

11 to the following non-CM/ECF participants:
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N/A

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/s/ Krista Busch
An employee of Marquis Aurbach

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