Manibusan v. Nevada Department of Corrections et al

Filing 65

ORDER granting ECF No. 64 Stipulation. Dispositive Motions are due by December 1, 2021. Signed by Magistrate Judge Carla Baldwin on 11/2/2021. (Copies have been distributed pursuant to the NEF - SMR)

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AARON D. FORD
Attorney General
STEPHEN J. AVILLO, Bar No. 11046
Deputy Attorney General
State of Nevada
100 N. Carson Street
Carson City, Nevada 89701-4717
Tel: [phone]
E-mail: [e-mail]
Attorneys for Defendants
Renee Baker, Dwayne Baze,
Tara Carpenter, James G. Cox,
James Dzurenda and Ronda Larsen

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARK MANIBUSAN,

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Case No. 3:17-cv-00303-MMD-CLB
Plaintiff,

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STIPULATION TO EXTEND DISPOSITIVE
MOTION DEADLINE
(FIRST REQUEST)

v.
NEVADA DEPARTMENT OF
CORRECTIONS, et al.,

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Defendants.

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Defendants, Renee Baker, Dwayne Baze, Tara Carpenter, James G. Cox, James Dzurenda and

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Ronda Larsen, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and

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Stephen J. Avillo, Deputy Attorney General, respectfully submit the following Stipulation and Order to

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Extend the Dispositive Motion deadline. The parties have previously stipulated to extend the discovery

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deadline, and this Stipulation is the first request for an extension of only the dispositive motion

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deadline. This stipulation is entered by the parties in good faith and not for the purpose of delay.

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Discovery in this matter concluded September 27, 2021, and dispositive motions are due

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November 1, 2021. ECF No. 63. Counsel for Plaintiff provided to counsel for Defendants amended

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initial disclosures on October 22, 2021. This late disclosure was the result of excusable oversight and

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not for the purpose of delay, and all documents included in the Amended Disclosures had been

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produced to counsel previously, before the close of discovery.

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Additionally, counsel for Defendants is in the process of transitioning to a different position

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within the Office of the Attorney General and has spent considerable time in the weeks leading up to

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the current deadline on that transition. The current matter is a complex matter by the standards of

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inmate litigation, and extending the dispositive motion deadline will allow the parties to fully brief the

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issues, utilizing all the discovery provided to date.
The parties submit that this stipulation is entered into in good faith and not for the purposes of

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delay.
Parties therefore stipulate to respectfully request a 30-day extension of the dispositive motion
deadline, to December 1, 2021.

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DATED this 28th day of October, 2021.
ROBERT L. LANGFORD & ASSOCIATES

AARON D. FORD
Attorney General

By: /s/ Matthew J. Rashbrook
MATTHEW J. RASHBROOK, ESQ.
Nevada Bar No. 12477
Attorneys for Plaintiff

By: /s/ Stephen J. Avillo
STEPHEN J. AVILLO, ESQ.
Nevada Bar No. 11132
Attorneys for the NDOC Defendants

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IT IS SO ORDERED.

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Dated: November 2, 2021

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________________________________________
UNITED STATES MAGISTRATE JUDGE

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CERTIFICATE OF SERVICE

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I certify that I am an employee of the Office of the Attorney General, State of Nevada, and that

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on this 1st day of November, 2021, I caused to be served a copy of the foregoing, STIPULATION TO

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EXTEND DISPOSITIVE MOTION DEADLINE (FIRST REQUEST), by U.S. District Court

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CM/ECF Electronic Filing to:

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Robert L. Langford
Matthew J. Rashbrook
Robert L. Langford & Associates
616 South Eighth Street
Las Vegas, NV 89101
[e-mail]
Attorneys for Plaintiff

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/s/ Roberta W. Bibee
An employee of the Office
of the Attorney General

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