Evans v. Dzurenda et al

Filing 35

ORDER granting ECF No. 34 Stipulation to Extend Briefing Schedule : Opening briefs due by 4/20/2020. Reply briefs due by 5/8/2020. Signed by Magistrate Judge William G. Cobb on 3/19/2020. (Copies have been distributed pursuant to the NEF - DRM)

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1 2 3 4 5 6 MARGARET A. MCLETCHIE, Nevada Bar No. 10931 ALINA M. SHELL, Nevada Bar No. 11711 MCLETCHIE LAW 701 East Bridger Ave., Suite 520 Las Vegas, Nevada 89101 Telephone: (702) 728-5300 Facsimile: (702) 425-8220 Email: maggie@nvlitigation.com Attorneys for Plaintiff Todd Evans 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 TODD EVANS, Plaintiff, 11 ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 Case No.: 3:18-cv-00283-RCJ-WGC STIPULATION AND ORDER TO EXTEND THE BRIEFING SCHEDULE (ECF No. 33) vs. JAMES DZURENDA, et al., 14 15 Defendants. (THIRD REQUEST) 16 17 Pursuant to LR IA 6-1, Plaintiff TODD EVANS and Defendants JAMES 18 DZURENDA, ROMEO ARANAS, JOHN KEAST, DR. JONES, and DR. MAR 19 (collectively “Defendants”), by and through their respective counsel, hereby stipulate and 20 request that this Court extend the deadline to file Opening Briefs (ECF No. 33) by an 21 additional thirty (30) days, extending the deadline from March 20, 2020 to April 20, 2020. 22 Parties further stipulate that the deadline for any responses shall be extended by twenty- 23 eight (28) days from April 10, 2020 (ECF No. 33) until May 8, 2020. This is the third 24 stipulation for extension of time for parties to file their Opening Briefs. 25 26 This Request for an extension of time is not sought for any improper purpose or other purpose of delay. This request for extension is based upon the following: 27 Counsel for Plaintiff TODD EVANS initiated this request due to conflicting 28 deadlines in other cases. Specifically, counsel Alina M. Shell is counsel in In Re: D.O.T. 1 1 Litigation (Eighth Judicial District Court Case No. A-19-787004-B). The court presiding 2 over In Re: D.O.T. Litigation has set a discovery deadline of March 13, 2020, and scheduled 3 a bench trial for April 20, 2020. The demands of completing discovery in this multi-party 4 consolidated case in advance of trial has interfered with counsel’s ability to complete the 5 opening brief in this matter. Additionally, the undersigned’s law office has recently begun 6 transitioning to working remotely in light of the ongoing COVID-19 public health 7 emergency. Accordingly, counsel requires additional time to adequately represent Mr. 8 Evans’ interests in this matter. 9 WHEREFORE, the parties respectfully request that this Court extend the deadline 10 to file Opening Briefs (ECF No. 33) to up to and including April 20, 2020 and any Responses 11 to be filed by May 8, 2020. ATTORNEYS AT LAW 701 EAST BRIDGER AVE., SUITE 520 LAS VEGAS, NV 89101 (702)728-5300 (T) / (702)425-8220 (F) WWW.NVLITIGATION.COM 12 13 IT IS SO STIPULATED. DATED this 18th day of March, 2020. DATED this 18th day of March, 2020. MCLETCHIE LAW ATTORNEY GENERAL’S OFFICE 14 15 16 17 18 19 20 /s/ Douglas R. Rands Aaron D. Ford, Nevada Attorney General Douglas R. Rands, Nevada Bar No. 3572 100 N. Carson Street Carson City, Nevada 89701-4717 Attorneys for Defendants /s/ Alina M. Shell Margaret A. McLetchie, NBN 10931 Alina M. Shell, NBN 11711 701 E. Bridger Ave., Suite 520 Las Vegas, NV 89101 Attorneys of Plaintiff Todd Evans 21 22 23 ORDER IT IS SO ORDERED. 24 25 26 27 28 HONORABLE JUDGE WILLIAM G. COBB U.S. DISTRICT COURT JUDGE DATED: March 19, 2020 2

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