Calleros v. City of North Las Vegas

Filing 59

ORDER granting 58 Stipulation TO EXTEND DEADLINES TO RESPOND AND REPLY TO DEFENDANTS MOTION FOR SUMMARY JUDGMENT ECF No. 44 (Fifth Request). IT IS FURTHER ORDERED that this Order granting Parties' Stipulation to Extend Deadlines is the last extension the Court will grant regarding the response and reply deadlines to Defendants Motion for Summary Judgment. Responses due by 12/16/2024. Replies due by 1/16/2025. Signed by Judge Gloria M. Navarro on 11/26/2024. (Copies have been distributed pursuant to the NEF - CAH)

1
2
3
4
5
6

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.

7
8
UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11

AUGUSTINE CALLEROS, JR.,

12
13
14

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]
(Fifth Request)

15
Defendant.

16
17

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

18
19

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

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

20

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

21

Judgment filed on August 28, 2024 [ECF No. 44] from the current deadline of November 25, 2024 up

22

to and including December 16, 2024. The parties further stipulate to extend the deadline for CNLV to

23
24

reply in support of its Motion for Summary Judgment from the current deadline of December 16, 2024
up to and including January 16, 2025. This Stipulation is made at the request of Plaintiff’s counsel for

25
26
27
28
Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

the reasons set forth herein. This is the fifth request to extend the deadline to respond to this dispositive
motion.
///
1 of 3

In support of this Stipulation and Order, the parties state as follows:

1

1.

2

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

3

Judgment filed on August 28, 2024 [ECF No. 44] is November 25, 2024. The parties have agreed to a

4

fifth extension of the deadline from the current deadline of November 25, 2024 until December 16,

5

2024.

6
7
8
9

2. Counsel for Plaintiff reached out to counsel for Defendant requesting an additional
extension of the response deadline due to an unexpected family emergency discussed in detail with
counsel for Defendant and in light of the fact that the Court recently extended the settlement conference

10

to February 20, 2025. Defendant’s counsel agreed to the requested extension. The parties also agreed

11

to extend the CNLV’s reply deadline due to the upcoming holidays and the parties agreed to a one

12

month extension of the reply deadline until January 16, 2024.

13
14

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

15
16
17

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 extension.

18

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

19

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

20

28, 2024 [ECF No. 44] from the current deadline of November 25, 2024 to December 16, 2024.

21
22
23
24
25

///

26

///

27

///

28
Melanie Hill Law PLLC
1925 Village Center Circle
Suite 150
Las Vegas, Nevada 89134
[phone]

2 of 3