Calleros v. City of North Las Vegas

Filing 57

ORDER granting 55 Stipulation TO EXTEND DEADLINES TO RESPOND AND REPLY TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT 44 (Fourth Request). IT IS SO ORDERED the deadline for Mr. Calleros to respond to Defendant's Motion for Summary Judgment filed on August 28, 2024 ECF No. 44 is November 25, 2024. Replies due December 16, 2024. Signed by Judge Gloria M. Navarro on 11/22/2024. (Copies have been distributed pursuant to the NEF - CAH)

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MELANIE A. HILL
Nevada Bar No. 8796
MELANIE HILL LAW PLLC
1925 Village Center Circle, Ste. 150
Las Vegas, Nevada 89134
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff Augustine Calleros, Jr.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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AUGUSTINE CALLEROS, JR.,

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

STIPULATION TO EXTEND DEADLINES
TO RESPOND AND REPLY TO
DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT [ECF No. 44]
(Fourth Request)

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Defendant.

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Plaintiff, Augustine Calleros, Jr. (“Calleros”), by and through his counsel, Melanie Hill Law,

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CASE NO.: 2:23-cv-01340-GMN-DJA

and Defendant City of North Las Vegas (“CNLV”), by and through its counsel, Madison Zornes-Vela,

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hereby stipulate to extend the deadline for Mr. Calleros to respond to Defendant’s Motion for Summary

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Judgment filed on August 28, 2024 [ECF No. 44] from the current deadline of November 21, 2024 up

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to and including November 25, 2024. The parties further stipulate to extend the deadline for CNLV to

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reply in support of its Motion for Summary Judgment from the current deadline of December 9, 2024
up to and including December 16, 2024. This Stipulation is made at the request of Plaintiff’s counsel

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

for the reasons set forth herein. This is the fourth request to extend the deadline to respond to this
dispositive motion.
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In support of this Stipulation and Order, the parties state as follows:

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The current deadline for Plaintiff to respond to the Defendant’s Motion for Summary

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Judgment filed on August 28, 2024 [ECF No. 44] is November 21, 2024. The parties have agreed to a

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fourth extension of the deadline from the current deadline of November 21, 2024 until November 25,

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2024.

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2. Counsel for Plaintiff reached out to counsel for Defendant requesting an additional two court
day extension of the response deadline due to Plaintiff’s counsel’s illness that formed the basis on the
third stipulation because it continued through this morning and kept counsel out of the office this week.

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Defendant’s counsel agreed to the requested extension. Counsel for Plaintiff also offered to extend the

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CNLV’s reply deadline due to the upcoming Thanksgiving holiday next week and the parties agreed to

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a 21-day extension of the reply deadline until December 16, 2024.

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3. This stipulation to extend the dispositive motion deadlines is brought in good faith, with a
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 the dispositive motion
considering the issues she has described herein constituting good cause for the short extension.

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

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deadline for Mr. Calleros to respond to Defendant’s Motion for Summary Judgment filed on August

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28, 2024 [ECF No. 44] from the current deadline of November 21, 2024 to November 25, 2024.

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

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