Speaks v. City of North Las Vegas

Filing 25

ORDER Granting 24 Stipulation for Extension of Time to Respond to 21 Motion to Dismiss, 22 Motion for Summary Judgment. Responses due by 9/27/2024. Signed by Judge Andrew P. Gordon on 8/29/2024. (Copies have been distributed pursuant to the NEF - AMMi)

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STIP
MELANIE A. HILL (Nevada Bar No. 8796)
MELANIE HILL LAW PLLC
1925 Village Center Circle, Suite 150
Las Vegas, Nevada 89134
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff Frazier S. Speaks, Jr.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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FRAZIER S. SPEAKS, JR.,

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CASE NO.: 2:23-cv-00887-APG-MDC
Plaintiff,

vs.
CITY OF NORTH LAS VEGAS, a municipal
corporation,

STIPULATION TO EXTEND DEADLINES
TO RESPOND TO CITY OF NORTH LAS
VEGAS’S MOTION TO DISMISS OR,
ALTERNATIVELY, MOTION FOR
SUMMARY JUDGMENT [ECF Nos. 21, 22]
(First Request)

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Defendant.

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Plaintiff, Frazier S. Speaks, Jr. (“Speaks”), by and through his counsel, Melanie Hill Law, and

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Defendant City of North Las Vegas (“CNLV”), by and through its counsel, Kaempfer Crowell, hereby

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stipulate to extend the deadlines for Mr. Speaks to respond to the City of North Las Vegas’s Motion

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to Dismiss, or, Alternatively, Motion for Summary Judgment filed on August 14, 2024 [ECF Nos. 21,
22] from the current deadlines of August 28, 2024 and September 4, 2024 respectively to September

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

27, 2024. This Stipulation is made at the request of Plaintiff’s counsel for the reasons set forth herein.
This is the first request to extend the deadlines to respond to these dispositive motions.
In support of this Stipulation and Order, the parties state as follows:
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The current deadlines to respond to the City of North Las Vegas’s Motion to

Dismiss, or, Alternatively, Motion for Summary Judgment filed on August 14, 2024 [ECF Nos. 21,
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22] is August 28, 2024 for the Motion to Dismiss and September 4, 2024 for the Motion for Summary

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Judgment. To deal with the discrepancy with these response deadlines being seven days apart pursuant

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to Local Rule LR 7-2, and given that the motions were combined into one pleading such that it makes

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the most sense to respond to them together, the parties have agreed to extend the deadlines thirty days

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from today’s date, August 28, 2024, which is Mr. Speaks’ current deadline to respond to the Motion

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to Dismiss [ECF No. 21].

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2. Counsel for Plaintiff reached out to counsel for Defendant requesting the thirty-day

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extension of the response deadlines and the parties have agreed to align the deadlines and grant Mr.
Speaks an extension until September 27, 2024 to respond to both motions.

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3. This stipulation to extend the dispositive motion deadlines is brought in good faith, with a

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showing of good cause, and is not sought for any improper purpose or other purpose of delay, but to

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allow counsel for the Plaintiff the additional time requested to respond to these two dispositive motions
and align the deadlines to September 27, 2024.

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

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WHEREFORE, the parties respectfully request by this stipulation that the Court extend the

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deadlines for Mr. Speaks to respond to the City of North Las Vegas’s Motion to Dismiss, or,

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Alternatively, Motion for Summary Judgment filed on August 14, 2024 [ECF Nos. 21, 22] from the

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current deadlines of August 28, 2024 and September 4, 2024 respectively to September 27, 2024.

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DATED this 28th day of August, 2024.
MELANIE HILL LAW PLLC

KAEMPFER CROWELL

By:

By: /s/ Lyssa S. Anderson
LYSSA S. ANDERSON
Nevada Bar No. 5781
RYAN W. DANIELS
Nevada Bar No. 13094
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135
Attorneys for Defendant
City of North Las Vegas

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/s/ Melanie A. Hill
MELANIE A. HILL
Nevada Bar No. 8796
1925 Village Center Circle, Ste. 150
Las Vegas, Nevada 89134
Attorneys for Plaintiff Frazier S.
Speaks, Jr.

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IT IS SO ORDERED:

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____________________________________
ANDREW P. GORDON
UNITED STATES DISTRICT JUDGE

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Dated: ___August 29, 2024____________

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Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

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