Castillo v. Western Range Association et al

Filing 146

ORDER granting ECF No. 145 Plaintiffs' Unopposed Motion for Extension of Time to Object to Bills of Cost [ECF Nos. 142 , 143 , and 144 ) and for Leave to File a Unified Objection. Plaintiffs' response due by 3/19/2018. Signed by Judge Robert C. Jones on 3/9/2018. (Copies have been distributed pursuant to the NEF - LH)

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THIERMAN BUCK LLP
MARK R. THIERMAN, ESQ.
Nevada State Bar No. 8285
[e-mail]
JOSHUA D. BUCK, ESQ.
Nevada State Bar No. 12187
[e-mail]
LEAH L. JONES, ESQ.
Nevada State Bar No. 13161
[e-mail]
7287 Lakeside Drive
Reno, Nevada 89511
Telephone: [phone]
Facsimile: [phone]

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CHRISTINE E. WEBBER, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
BRIAN CORMAN, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
COHEN MILSTEIN SELLERS & TOLL PLLC
1100 New York Ave., NW, Ste 500
Washington, DC 20005

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TOWARDS JUSTICE
ALEXANDER HOOD, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
1535 High Street, Ste. 300
Denver, CO 80218

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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ABEL CANTARO CASTILLO; ALCIDES INGA
RAMOS, and those similarly situated,

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Plaintiffs,

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vs.

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WESTERN RANGE ASSOCIATION; MELCHOR
GRAGIRENA; EL TEJON SHEEP COMPANY;
MOUNTAIN PLAINS AGRICULTURAL
SERVICE; ESTILL RANCHES, LLC; and JOHN
ESTILL,
Defendants.

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CASE NO. 3:16-cv-00237-RCJ-VPC
Unopposed Motion for Extension of Time
to Object to Bills of Cost and for Leave to
File a Unified Objection

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After the Court’s order dismissing Plaintiffs’ claims, Defendants filed three bills of cost and

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Plaintiffs’ objections are currently due on March 12, 2018 and March 13, 2018. See Docs. 142, 143,

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144. Plaintiffs request leave to file a single unified objection to all three bills of cost and for an

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extension until March 19, 2018 to file the unified objection. This is the first motion to extend time to
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object to the bills of cost.
Plaintiffs intend to object to the bills of cost, at least in part, based on their inability to pay.

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See Stanley v. University of Southern California, 178 F. 3d 1069, 1079 (9th Cir. 1999). Because

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some Plaintiffs currently reside in remote areas of Peru, Plaintiffs need the extra time to supply their

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attorneys with evidence of that inability to pay for submission to the Court. Plaintiffs additionally
request that they be permitted to file a unified objection because arguments regarding ability to pay

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will be the same or similar across all objections and a unified objection will therefore be more
efficient for the Court to consider. Prior to filing, Plaintiffs conferred with all Defendants regarding
this Motion. Defendants do not oppose this Motion.
Plaintiffs therefore request that:
1. Their deadline to respond to all of Defendants’ bills of cost (Docs. 142, 143, 144) be
extended to March 19, 2018; and
2. They be granted leave to file a single unified response to Defendants’ bills of cost

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(Docs. 142, 143, 144).
Dated this 7th day of March, 2018
_/s/Alexander Hood___________
TOWARDS JUSTICE
ALEXANDER HOOD, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
1535 High Street, Ste. 300
Denver, CO 80218

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COHEN MILSTEIN SELLERS & TOLL PLLC
CHRISTINE E. WEBBER, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
BRIAN CORMAN, ESQ.
(Admitted Pro Hac Vice)
[e-mail]
1100 New York Ave., NW, Ste 500
Washington, DC 20005

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THIERMAN BUCK LLP
MARK R. THIERMAN, ESQ.
Nevada State Bar No. 8285
[e-mail]
JOSHUA D. BUCK, ESQ.
Nevada State Bar No. 12187
[e-mail]
LEAH L. JONES, ESQ.
Nevada State Bar No. 13161
[e-mail]
7287 Lakeside Drive
Reno, Nevada 89511
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs

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IT IS SO ORDERED:

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_____________________________________________
The Honorable Robert C. Jones
UNITED STATES DISTRICT JUDGE
DATED: _________________
March 9, 2018

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