Freeman v. Field Service Agents

Filing 44

ORDER granting 43 Stipulation to Extend Dispositive Motion Deadline. Motions due by 12/22/2020. Proposed Joint Pretrial Order due by 1/21/2021. Signed by Magistrate Judge William G. Cobb on 10/6/2020. (Copies have been distributed pursuant to the NEF - HJ)

1
2
3
4
5
6
7

LYSSA S. ANDERSON
Nevada Bar No. 5781
RYAN W. DANIELS
Nevada Bar No. 13094
KAEMPFER CROWELL
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135
Telephone: [phone]
Fax:
[phone]
[e-mail]
[e-mail]
Attorneys for Defendants
Armando Lozano-Carrera and Milton Hsieh

8
9

UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA

11

VINCENT FREEMAN, II,

CASE NO.:

3:18-cv-00192-MMD-WGC

Plaintiff,

12
vs.
13

15

ARMANDO LOZANO-CARRERA, in his
individual and official capacities; and
MILTON HSIEH, in his individual and
official capacities; et al.

16

STIPULATION AND ORDER TO
EXTEND DISPOSITIVE MOTION
DEADLINE

Defendants.

14

(First Request)

Vincent Freeman II (“Plaintiff”) agree and stipulate to extend the dispositive motion deadline

19

currently set for October 28, 2020 for fifty five days making the new dispositive motion deadline

20

December 22, 2020. The extension is being requested because Plaintiff recently served a

21
KAEMPFER CROWELL

Defendants Armando Lozano-Carrera and Milton Hsieh (the “LVMPD Defendants”) and

18

1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

17

subpoena to the Regional Justice Center seeking any video evidence of the incident claimed by

22

Plaintiff in this lawsuit. The parties agree that if the Regional Justice Center produces any video

23

footage of the incident, such footage could resolve some issues and potentially impact any

24

dispositive motion.

2640181_1 6943.184

Page 1 of 2

1

The Regional Justice Center has until November 22, 2020 to respond to the subpoena so

2

the parties agree that the dispositive motion deadline should be extended by thirty days after the

3

response deadline to file a dispositive motion. Thirty days after November 22, 2020 is December

4

22, 2020.

5

The parties request this extension prior to the expiration of the twenty-one deadline as

6

forth in LR 26-4. As mentioned above, there is good cause for the extension because video

7

evidence produced by the Regional Justice Center may resolve issues on a dispositive motion. As

8

such, the extension will not prejudice any party and may potentially help the parties properly

9

brief their dispositive motions for this Court. The parties are not delaying the conclusion of this

10
11

matter; no trial date has yet been ordered.
DATED this 6th day of October, 2020.

12

KAEMPFER CROWELL

13

By: /s/ Ryan W. Daniels
LYSSA S. ANDERSON
Nevada Bar No. 5781
RYAN DANIELS
Nevada Bar No. 13094
1980 Festival Plaza Drive, #650
Las Vegas, Nevada 89135
Attorneys for Defendants
Armando Lozano-Carrera and Milton
Hsieh

14
15
16
17

By: /s/ Travis N. Barrick
Travis N. Barrick, Esq.
Nevada Bar No. 9257
GALLIAN WELKER, & BECKSTROM
540 E. St. Louis Avenue
Las Vegas, Nevada 89104
Attorney for Plaintiff Vincent Freeman

18
IT IS SO ORDERED.
19
20

DATED: October 6, 2020.

KAEMPFER CROWELL

1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

21
UNITED STATES MAGISTRATE JUDGE

22
23
24

2640181_1 6943.184

Page 2 of 2