Walden et al v. State of Nevada, et al

Filing 298

ORDER - The Stipulation (ECF No. 297 ) is granted as follows: Plaintiff's Opposition to the Motion to Exclude (ECF No. 282 ) due by May 13, 2020 and Defendant's Reply due by May 27, 2020.Defendant's Reply to the Motion of Summary Judgment (ECF No. 276 ) due by June 3, 2020. Opposition deadline shall remain unchanged, due 5/13/2020.Defendant's Reply to the Motion for Summary Judgment (ECF No. 283 ) due by June 10, 2020. Oppositi on deadline shall remain unchanged, due 5/20/2020.Signed by Chief Judge Miranda M. Du on 5/6/2020. (Copies have been distributed pursuant to the NEF - AB) Modified on 5/7/2020 to include that ECF No. 297 Stipulation was granted, NEF regenerated to parties (AB).

Case 3:14-cv-00320-MMD-WGC Document 298 Filed 05/06/20 Page 1 of 3

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THIERMAN BUCK LLP
Mark R. Thierman, Nev. Bar No. 8285
[e-mail]
Joshua D. Buck, Nev. Bar No. 12187
[e-mail]
Leah L. Jones, Nev. Bar No. 13161
[e-mail]
7287 Lakeside Drive
Reno, Nevada 89511
Tel. [phone]
Fax. [phone]

WILSON ELSER MOSKOWITZ,
EDELMEN & DICKER LLP
Sheri M. Thome, Esq., Nev. Bar No. 008657
James T. Tucker, Esq., Nev Bar No. 012507
Cara T. Laursen, Esq., Nev Bar No. 014563
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Plaintiffs

Attorneys for Defendant The State of Nevada,
ex rel. its Department of Corrections

THIERMAN BUCK LLP
7287 Lakeside Drive
Reno, NV 89511
[phone] Fax [phone]
Email [e-mail] www.thiermanbuck.com

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DONALD WALDEN JR, NATHAN
ECHEVERRIA, AARON DICUS, BRENT
EVERIST, TRAVIS ZUFELT, TIMOTHY
RIDENOUR, and DANIEL TRACY on behalf
of themselves and all others similarly situated,

Case No.: 3:14-cv-00320-MMD-WGC
STIPULATION FOR ENLARGEMENT
OF TIME FOR RESPONSIVE MOTIONS
AND [PROPOSED] ORDER THEREON
(Second Request)

Plaintiffs,
v.
THE STATE OF NEVADA, EX REL. ITS
NEVADA DEPARTMENT OF
CORRECTIONS, and DOES 1-50,
Defendants.

Plaintiffs DONALD WALDEN JR., NATHAN ECHEVERRIA, AARON DICUS,
BRENT EVERIST, TRAVIS ZUFELT, TIMOTHY RIDENOUR, and DANIEL TRACY on
behalf of themselves and all other similarly situated, and Defendant STATE OF NEVADA, EX.

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REL. ITS DEPARTMENT OF CORRECTIONS (collectively “The Parties), by and through their

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respective counsel of record, hereby stipulate and agree to extend the time for both Parties to file

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their respective responsive pleadings as set forth below.
- 1 STIPULATION AND ORDER TO FOR EXTENSION OF TIME FOR RESPONSIVE PLEADINGS

Case 3:14-cv-00320-MMD-WGC Document 298 Filed 05/06/20 Page 2 of 3

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This stipulation is submitted in compliance with LR IA 6-1. The Parties are requesting

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these extension due to the volume of motions pending, the complexity and fact intensive nature

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of the responsive pleadings, counsels’ professional commitments, existing workload, and the

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continued challenges of working remotely due to the COVID-19 crisis, including slower

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connectivity, communications delays, and obtaining records necessary to the motions. Good

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cause exists for the requested extensions.1

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Accordingly, the Parties further stipulate and agree to extend the deadlines as follows:

THIERMAN BUCK LLP
7287 Lakeside Drive
Reno, NV 89511
[phone] Fax [phone]
Email [e-mail] www.thiermanbuck.com

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1.

Plaintiffs’ Opposition to NDOC’s Motion to Exclude Evidence from Plaintiffs’

Expert ERC (ECF No. 282) currently due 5/6/20 shall be extended one (1) week to on or before
Wednesday, May 13, 2020. Defendant’s Reply In Support Of shall be due on or before
Wednesday, May 27, 2020.
2.

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Plaintiffs’ Opposition to NDOC’s Motion for Summary Judgment on Sovereign

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Immunity (ECF No. 276) currently due 5/13/20 which shall remain unchanged. The Parties

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request that Defendant’s Reply In Support Of shall be due on or before Wednesday, June 3,

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2020.

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The Court granted the Parties First Request for Extension of time on 4/13/20 at ECF No. 287.
- 2 STIPULATION AND ORDER TO FOR EXTENSION OF TIME FOR RESPONSIVE PLEADINGS

Case 3:14-cv-00320-MMD-WGC Document 297 Filed 05/05/20 Page 3 of 3
Case 3:14-cv-00320-MMD-WGC Document 298 Filed 05/06/20 Page 3 of 3

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3.

Plaintiffs’ Opposition to NDOC’s Motion for Summary Judgment on the Merits

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of Plaintiffs FLSA Claims (ECF No. 283) currently due 5/20/20 which shall remain unchanged.

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The Parties request that Defendant’s Reply In Support Of shall be due on or before

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Wednesday, June 10, 2020.

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THIERMAN BUCK LLP
7287 Lakeside Drive
Reno, NV 89511
[phone] Fax [phone]
Email [e-mail] www.thiermanbuck.com

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The Parties agree that the requested extension furthers the interest of this litigation and is
not being requested in bad faith or to delay these proceedings unnecessarily.
IT IS SO STIPULATED.
Dated: May 5, 2020.

Dated: May 5, 2020.

THIERMAN BUCK LLP

WILSON ELSER MOSKOWITZ,
EDELMEN & DICKER LLP

/s/Leah L. Jones
Mark R. Thierman, Esq., Bar No. 8285
Joshua D. Buck, Esq., Bar No. 12187
Leah L. Jones, Esq., Bar No. 13161
7287 Lakeside Drive
Reno, Nevada 89511
Tel. [phone]
Fax. [phone]

/s/James T Tucker
Sheri M. Thome, Esq., Bar No. 008657
James T. Tucker, Esq., Bar No. 012507
Cara T. Laursen, Esq., Bar No. 014563
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
Attorneys for Defendants

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Attorneys for Plaintiffs

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ORDER

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IT IS SO ORDERED.

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6th
Dated this ____ day of May

, 2020.

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U.S. District Judge

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- 3 STIPULATION AND ORDER TO FOR EXTENSION OF TIME FOR RESPONSIVE PLEADINGS