Bement v. Cox et al

Filing 119

ORDER granting Stipulation (ECF No. 118 ) : Proposed joint pretrial order due 30 days after the Court rules on NDOC's Motion for Reconsideration (ECF No. 117 ). Signed by Chief Judge Miranda M. Du on 5/6/2020. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:12-cv-00475-MMD-WGC Document 119 Filed 05/06/20 Page 1 of 2

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ARRON D. FORD
Attorney General
KEVIN A. PICK (Bar No. 11683)
Senior Deputy Attorney General
CAMERON P. VANDENBERG (Bar. No. 4356)
Chief Deputy Attorney General
State of Nevada
Office of the Attorney General
5420 Kietzke Lane, Suite 202
Reno, Nevada 89511
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant Nevada
Department of Corrections

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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BARON BEMENT,

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Case No. 3:12-cv-00475-MMD-WGC
Plaintiff,

vs.

STIPULATION AND ORDER TO
EXTEND JOINT PRETRIAL ORDER
DEADLINE (FIRST REQUEST)

THE STATE OF NEVADA DEPARTMENT
OF CORRECTIONS,
Defendants.

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Defendant, State of Nevada Department of Corrections (“NDOC”), by and through its

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attorneys, Aaron D. Ford, Attorney General for the State of Nevada, Kevin A. Pick, Senior

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Deputy Attorney General, and Cameron P. Vandenberg, Chief Deputy Attorney General, and

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Plaintiff, Baron Bement, by and through his counsel Brian R. Morris, Esq., hereby stipulate and

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agree that the current May 8, 2020, deadline to file the parties’ proposed joint pretrial order be

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extended until 30 days after the Court enters its decision on NDOC’s Motion for

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Reconsideration (ECF No. 117), which was filed on May 5, 2020.

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NDOC’s Motion for Reconsideration asks this Court to reconsider the April 8, 2020,

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Order (ECF No. 116) denying summary judgment and instructing that this case proceed to trial.

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See ECF No. 117. As such, any order regarding NDOC’s Motion for Reconsideration will

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necessarily involve (and possibly impact) many of the required sections in the proposed joint
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Case 3:12-cv-00475-MMD-WGC Document 119 Filed 05/06/20 Page 2 of 2

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pretrial order, including the contested issues of law and fact, the necessary exhibits, the

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necessary witnesses, and the length of the trial. As such, the parties agree that judicial economy

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and good cause support extending the current deadline for the proposed joint pretrial order until

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30 days after the Court rules on NDOC’s Motion for Reconsideration.

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Additionally, good cause also exists for this stipulated extension due to the fact that the

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undersigned counsel for NDOC recently returned from 30 days of paternity leave ending on

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April 24, 2020, and did not have the benefit of the full 30 day period to prepare the proposed

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joint pretrial order, as set forth in the Court’s April 8, 2020, Order. Furthermore, the ability of

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the undersigned counsel for NDOC to prepare the proposed joint pretrial order has been

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hindered by the current pandemic, including the Governor’s stay at home order.
DATED this 6th day of May 2020.
AARON D. FORD
Attorney General
By: /s/ Kevin A. Pick
KEVIN A. PICK (Bar. No. 11683)
Senior Deputy Attorney General
CAMERON P. VANDENBERG
(Bar. No. 4356)
Chief Deputy Attorney General
Attorneys for Defendant NDOC

/s/ Brian R. Morris, Esq.
Brian R. Morris, Esq.
5455 S. Fort Apache Road, #108-151
Las Vegas, NV 89148
Tele: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff

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ORDER

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IT IS SO ORDERED.

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DATED: ___________________, 2020.
May 6, 2020

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___________________________________
UNITED STATES DISTRICT JUDGE

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