Opinion
2:20-CV-01381-KJD-VCF
04-04-2023
PAUL LEWIS BROWNING, Plaintiff, v. LAS VEGAS METROPOLITAN POLICE DEPARTMENT et al., Defendants.
Luke A. Busby, ESQ Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff David B. Owens Counsel for Plaintiff Paul Browning Craig Anderson One of Defendants' Attorneys
Luke A. Busby, ESQ Luke Andrew Busby, Ltd. Designated Resident Nevada Counsel for Plaintiff
David B. Owens Counsel for Plaintiff Paul Browning
Craig Anderson One of Defendants' Attorneys
Hon. Kent J. Dawson Judge
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE REPLY IN SUPPORT OF PLAINTIFF'S MOTION FOR LEAVE TO AMEND COMPLAINT (FIRST REQUEST)
Hon. Cam Ferenbach Judge
Pursuant to Local Rule IA 6-1, the parties, by and through their counsel of record, hereby agree and stipulate that the time for Bettie Browning, Administrator of the Estate of Paul Browning, to file her reply in support of Plaintiff's Motion for Leave to Amend Complaint (ECF No. 64), which was filed on March 1, 2023, should be extended by one week-from April 7, until and including April 14, 2023. The following grounds constitute good cause:
1. On March 1, 2023, Plaintiff filed a Motion for Leave to File an Amended Complaint (ECF No. 64). Pursuant to Local Rule 7-2(b), Defendants' response was due on March 15, 2023.
2. On March 6, 2023, Defendants filed a stipulation extending the deadline to file their response from March 15, 2023 to March 31, 2023 (ECF No. 65).
3. While Plaintiff's counsel have endeavored to file their reply by the current deadline of April 7, 2023, they are occupied with other time-sensitive matters, including an appellate brief in Lobato v. LVMPD - due on April 5, 2023 -along with an appellate brief in Apolo-Albino v. State of Washington and a reply brief in Simmers v. King County, both due on April 6, 2023.
4. This stipulation is not brought for any improper purpose, but rather to ensure that both sides to this matter are permitted the benefit of appropriate review of relevant evidence and the time to clearly and adequately lay out the issues for the Court's resolution.
5. Plaintiff's counsel have conferred with counsel for Defendants, and the parties have agreed to this extension. Accordingly, Plaintiff and Defendants stipulate that Plaintiff's deadline to file the reply in support of the Motion for Leave to Amend Complaint should be extended until April 14, 2023. This stipulation is made in good faith and not for the purpose of delay.
ORDER
IT IS SO ORDERED that the above Stipulation is hereby GRANTED. Plaintiff shall have until April 14, 2023, to file a reply in support of the Motion for Leave to Amend Complaint.