Fernandez v. Jackson et al
Filing
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ORDER on ECF No. 49 Stipulation : Settlement documents due by 12/3/2018. Signed by Magistrate Judge William G. Cobb on 11/27/2018. (Copies have been distributed pursuant to the NEF - DRM)
Case 3:13-cv-00670-RCJ-WGC Document 49 Filed 11/26/18 Page 1 of 3
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ADAM PAUL LAXALT
Attorney General
ERIN L. ALBRIGHT, Bar No. 9953
Deputy Attorney General
State of Nevada
Bureau of Litigation
Public Safety Division
100 N. Carson St.
Carson City, NV 89701-4717
Tel: 775-684-1257
E-Mail: ealbright@ag.nv.gov
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Attorneys for Defendants
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UNITED STATES DISTRICT COURT
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KEVIN FERNANDEZ,
Plaintiff,
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STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
STIPULATION AND ORDER OF
DISMISSAL WITH PREJUDICE
(SECOND FINAL REQUEST)
v.
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DISTRICT OF NEVADA
3:13-cv-670-RCJ-WGC
Case No.: 3:13-cv-00670-MMD-VPC
BERT JACKSON, et al.,
Defendants.
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Defendants by and through its counsel of record, Adam Paul Laxalt, Attorney General of the
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State of Nevada, and Erin L. Albright, Deputy Attorney General, and Plaintiff, Kevin Fernandez, by
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and through his counsel of record, Joseph Reiff, Esq., hereby stipulate to extend the time to file the
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Stipulation and Order of Dismissal with Prejudice by one week.
On September 18, 2018, defense counsel provided plaintiff’s counsel with the revised settlement
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agreement that reflected the majority of the changes requested by Plaintiff.
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plaintiff’s counsel provided the settlement agreement to the New Hampshire prison for delivery to
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Plaintiff.
On October 29, 2018, defense counsel received Plaintiff’s requested changes to the revised
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On the same date,
settlement agreement.
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In early November 2018, the parties scheduled a conference call to finalize the terms of the
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settlement agreement. On November 13, 2018, the parties held a conference call and finalized the
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terms of the agreement. During this phone call, Plaintiff was advised that defense counsel would not
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Case 3:13-cv-00670-RCJ-WGC Document 49 Filed 11/26/18 Page 2 of 3
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return to the office until November 26, 2018. After the phone call, the revised agreement was promptly
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provided to Plaintiff.
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On November 20, 2018, while defense counsel was out of the office, Plaintiff sent an email
requesting additional changes to the settlement agreement.
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On November 26, 2018, defense counsel reviewed Plaintiff’s requested changes defense counsel
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and Plaintiff’s counsel have scheduled to discuss the revisions as some but not all of the revisions can
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be made. Since the requested revisions are minor, the parties believe no more than a week is required
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to execute the settlement documents.
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Since the settlement documents must be filed today and the parties will not have time to discuss
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and finalize the requested changes, the parties respectfully request this Court extend the deadline to file
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the Stipulation and Order of Dismissal to December 3, 2018.
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DATED this 26th day of November, 2018.
DATED this 26th day of November, 2018.
PLAINTIFF, KEVIN FERNANDEZ
OFFICE OF THE ATTORNEY GENERAL
By: _/s/ Joseph Reiff_______________
Joseph Reiff, Esq.
Representing, Plaintiff, Kevin Fernandez
By: _/s/ Erin L. Albright__________
Erin L. Albright, SBN 9953
100 N. Carson Street
Carson City, NV 89701
(775) 684-1257
ealbright@ag.nv.gov
Attorneys for Defendants
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IT IS SO ORDERED.
DATED this _____ day of _____________, 2018.
DATED: November 27, 2018.
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___________________________________
____________________________________________
DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
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