Evans v. Dzurenda et al

Filing 53

ORDER granting ECF No. 52 Stipulation. Plaintiff has up to and including August 10, 2020 to file his Amended Complaint. Signed by Magistrate Judge William G. Cobb on 7/9/2020. (Copies have been distributed pursuant to the NEF - AB)

Case 3:18-cv-00283-RCJ-WGC Document 53 Filed 07/09/20 Page 1 of 2

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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: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiff Todd Evans

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TODD EVANS,
Plaintiff,

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ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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Case No.: 3:18-cv-00283-RCJ-WGC

STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
AMENDED COMPLAINT
(ECF No. 41)

vs.
JAMES DZURENDA, et al.,

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Defendants.

(SECOND REQUEST)

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Pursuant to LR IA 6-1, Plaintiff TODD EVANS and Defendants JAMES

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DZURENDA, ROMEO ARANAS, JOHN KEAST, DR. JONES, and DR. MAR

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(collectively “Defendants”), by and through their respective counsel, hereby stipulate and

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request that this Court extend the deadline for Plaintiff TODD EVANS to file his Amended

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Complaint, pursuant to Screening Order (ECF No. 41), by an additional thirty (30) days,

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extending the deadline from July 10, 2020 to August 10, 2020.

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This Request for an extension of time is not sought for any improper purpose or

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other purpose of delay. This is the second request for an extension in this matter. This request

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for extension is based upon the following:

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Counsel for Plaintiff TODD EVANS initiated this request due to conflicting

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deadlines in other cases. Specifically, counsel Alina M. Shell is counsel in In Re: D.O.T.

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Litigation (Eighth Judicial District Court Case No. A-19-787004-B). Trial in that matter was

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Case 3:18-cv-00283-RCJ-WGC Document 53 Filed 07/09/20 Page 2 of 2

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originally scheduled to begin on April 20, 2020. In light of the COVID-19 pandemic, that

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trial deadline was stayed indefinitely. However, on June 22, 2020, the district court notified

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the parties that trial in the In re: D.O.T. Litigation will begin on July 13, 2020, and will be

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conducted at an off-site location to comply with the social distancing guidelines promulgated

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by the Eighth Judicial District Court. Since the district court set trial in the In re: D.O.T.

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Litigation matter for July 13, 2020, the undersigned has had to dedicate substantial time to

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pretrial filings, completing depositions, participating in pretrial hearings, and other matters

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related to trial. Accordingly, counsel requires additional time to adequately represent Mr.

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Evans’ interests in this matter.

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WHEREFORE, the parties respectfully request that this Court extend the deadline
for Plaintiff to file his Amended Complaint to up to and including August 10, 2020.

ATTORNEYS AT LAW
701 EAST BRIDGER AVE., SUITE 520
LAS VEGAS, NV 89101
[phone] (T) / [phone] (F)
WWW.NVLITIGATION.COM

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IT IS SO STIPULATED.

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DATED this 9th day of July, 2020.

DATED this 9th day of July, 2020.

MCLETCHIE LAW

ATTORNEY GENERAL’S OFFICE

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/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

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ORDER
IT IS SO ORDERED.

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HONORABLE JUDGE WILLIAM G. COBB
U.S. MAGISTRATE JUDGE

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DATED: July 9, 2020

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