Opinion
2:20-cv-02149-KJD-NJK
01-19-2022
Jeff Corbett, an individual; John Jenkins, an individual; Scott Murray, an individual; and David Newton, an individual, Plaintiffs, v. Public Employees' Retirement System, ex rel. State of Nevada; Las Vegas Metropolitan Police Department, a political subdivision of the State of Nevada; and Does I - X; inclusive, Defendants.
Marquis Aurbach Nick D. Crosby, Esq. Nevada Bar No. 8996 Attorneys for Defendant LVMPD CHRISTENSEN JAMES & MARTIN, CHTD. Daryl E. Martin, Esq. Nevada Bar No. 6735 Evan L. James, Esq. Nevada Bar No. 7760 Attorneys for Plaintiffs, Jeff Corbett, John Jenkins, Scott Murray and David Newton
Marquis Aurbach
Nick D. Crosby, Esq.
Nevada Bar No. 8996
Attorneys for Defendant LVMPD
CHRISTENSEN JAMES & MARTIN, CHTD.
Daryl E. Martin, Esq.
Nevada Bar No. 6735
Evan L. James, Esq.
Nevada Bar No. 7760
Attorneys for Plaintiffs, Jeff Corbett, John Jenkins, Scott Murray and David Newton
STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTION DEADLINE
Defendant Las Vegas Metropolitan Police Department, (the "Department" or "LVMPD"), by and through its counsel of record, Nick D. Crosby, Esq., of the law firm of Marquis Aurbach; and Plaintiffs, Jeff Corbett, John Jenkins, Scott Murray and David Newton (collectively "Plaintiffs"), by and through their counsel of record, Daryl E. Martin, Esq. of the law firm of Christensen James & Martin, Chtd., respectfully submit this Stipulation and Order to Extend the Dispositive Motion Deadline.
I. REASONS FOR THE REQUESTED EXTENSION OF TIME
The parties are addressing a discovery dispute that was raised on December 28, 2021 by Plaintiffs. Counsel conducted a meet and confer on January 7, 2022 and discussed the issues raised by Plaintiffs. Pursuant to counsel's meet and confer, and to avoid the need for court intervention in the discovery dispute, Defendants are supplementing certain responses to discovery. In order to avoid having an incomplete discovery record while preparing dispositive motions, and to afford time for the parties to resolve the discovery dispute while not losing time to prepare and file dispositive motions, the Parties respectfully request the Court extend the dispositive motion/joint pretrial order deadline in this matter by 60 days. This extension is brought in good faith and not for purposes of delay and, instead, is sought to allow sufficient time for the parties to successfully resolve the discovery dispute without the need for court intervention, while also allowing sufficient time for the parties to prepare dispositive motions, should they so desire.
II. PROPOSED SCHEDULE
With the above in mind, the Parties hereto agree to extend the current Dispositive Motion deadline 60 days from January 27, 2022 to March 28, 2022.
In accordance with LR 26-1(e)(5), the last day to file a Joint Pretrial Order shall be April 27, 2022. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days after decision on the dispositive motion or upon further Order by the Court extending the time period in which to file the Joint Pretrial Order.
This request is not sought for any improper purpose or for the purpose of delay. The Parties respectfully submit that the reasons set forth above constitute good cause for the extended deadlines requested above.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.