Opinion
2:20-CV-01381-KJD-VCF
01-24-2023
BROWNING, Plaintiff, v. LAS VEGAS METROPOLITAN POLICE DEPARTMENT et al., Defendants.
David B. Owens California Bar No. 275030 Counsel for Plaintiff Paul Browning Luke A. Busby, ESQ Nevada Bar No. 10319 Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff Elizabeth Wang Counsel for Plaintiff Craig R. Anderson Counsel for Defendants David B. Owens* California Bar No. 275030 Counsel for Plaintiff Elizabeth Wang* Loevy & Loevy Counsel for Plaintiff *Admitted pro hac vice Luke A. Busby, ESQ Nevada Bar No. 10319 Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff Craig R. Anderson, Esq. Marquis Aurbach Coffing Nevada Bar No. 6882 Counsel for Defendants
David B. Owens California Bar No. 275030 Counsel for Plaintiff Paul Browning
Luke A. Busby, ESQ Nevada Bar No. 10319 Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff
Elizabeth Wang Counsel for Plaintiff
Craig R. Anderson Counsel for Defendants
David B. Owens* California Bar No. 275030 Counsel for Plaintiff
Elizabeth Wang* Loevy & Loevy Counsel for Plaintiff *Admitted pro hac vice
Luke A. Busby, ESQ Nevada Bar No. 10319 Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff
Craig R. Anderson, Esq. Marquis Aurbach Coffing Nevada Bar No. 6882 Counsel for Defendants
STIPULATION AND ORDER TO EXTEND DEADLINE FOR RESPONSE TO DISPOSITIVE MOTION (FIRST REQUEST)
KENT J. DAWSON, UNITED STATES DISTRICT JUDGE
Now comes Betty Browning, Administrator of the Estate of Paul Browning, and Defendants, by and through their respective undersigned counsel, hereby and stipulate and agree that the response deadline for Plaintiff's response to Defendants' motion for summary judgment should be extended, and state as follows:
1. Defendants filed a 54-page motion for summary judgment on January 6, 2023. Dkt. 61.
2. Under the Local Rules, Plaintiff's response to the motion is due on January 27, 2023. LR 7-2(b).
3. Plaintiff requests that the deadline for the response to the motion be extended to March 10, 2023.
4. Good cause exists for granting this extension of time, including the extensive length and nature of the dispositive motion itself. In addition, Plaintiff's counsel have other obligations over the next month that will preclude completion of the response on January 27, or in February. Some (though not all) of these obligations include: Plaintiff's counsel (Elizabeth Wang) is preparing for trial in Frasier v. Evans, No. 15-cv-1759-REB-KLM (D. Colo.), which is set for February 27, 2023, and currently in the midst of preparation of pretrial materials such as the Final Pretrial Order, exhibit and witness lists, jury instructions and motions in limine briefing. Plaintiff's counsel also has a Tenth Circuit brief due in Epps, et al. v. Budaj, et al., No. 22-1365 (10th Cir.), on February 6, 2023, and Daubert motions due in Cruz v. City and County of Denver, et al., No. 21-cv-3388-KLM (D. Colo.), on February 1, 2023. Plaintiff's other counsel (David B. Owens) has Daubert and other motions due on January 20, 2023, in Fatai v. City and County of Honolulu, 19CV603 (D. Haw.), responses to three post-trial motions in Gillispie v. Miami Township, 13CV416 (S.D. Ohio) due on January 24, 2023, and an appellate brief due in Washington state court in Apolo-Albino v. State of Washington, No. 835521 (Div. I) on January 30, 2023.
5. This request is not being submitted to unduly delay or prejudice any party but to ensure that Plaintiff has an adequate opportunity to present a fulsome response to Defendants' 54-page motion seeking the entire dismissal of this important civil rights suit.
IT IS SO ORDERED.