Opinion
2:22-cv-01419-CDS-DJA
08-04-2023
JOSE ALEXANDER ESCOBAR, Plaintiff v. UNITED STATES OF AMERICA; DOES I through XX, inclusive; and ROE BUSINESS ENTITIES I through XX, inclusive, Defendant
LADAH LAW FIRM RAMZY P. LADAH, ESQ. DANIEL C. TETREAULT, ESQ. ATTORNEYS FOR PLAINTIFF JASON M. FRIERSON UNITED STATES ATTORNEY STEPHEN R. HANSON II, ESQ. ASSISTANT UNITED STATES ATTORNEY
LADAH LAW FIRM RAMZY P. LADAH, ESQ. DANIEL C. TETREAULT, ESQ. ATTORNEYS FOR PLAINTIFF
JASON M. FRIERSON UNITED STATES ATTORNEY STEPHEN R. HANSON II, ESQ. ASSISTANT UNITED STATES ATTORNEY
ORDER GRANTING STIPULATION FOR CONTINUANCE OF JOINT PRE-TRIAL ORDER DEADLINE
(Second Request)
[ECF No. 14]
Plaintiff Jose Alexander Escobar and Defendant United States of America, by and through their undersigned counsel, hereby agree and stipulate to extend the deadline to file the joint pretrial order from August 7, 2023, to September 7, 2023. This is the second request to extend the deadline for the joint pretrial order. The basis for the requested extension is set forth below in the Declaration of Daniel C. Tetreault, Esq., counsel for Plaintiff Jose Alexander Escobar.
Discovery closed in this matter on May 8, 2023. The joint pretrial order is currently due on July 7, 2023. The reason for this stipulation is that the parties are currently in settlement discussions, and the joint pretrial order will be unnecessary if the parties reach a settlement in this case.
DECLARATION OF DANIEL C. TETREAULT, ESQ IN SUPPORT OF REQUEST TO CONTINUE DEADLINE FOR JOINT PRE-TRIAL ORDER
DANIEL C. TETREAULT, ESQ., being first duly sworn, deposes and says:
1. I am an attorney duly licensed to practice law in the State of Nevada, and in the federal District Court in and for the District of Nevada. I am counsel for Plaintiff, JOSE ALEXANDER ESCOBAR, in Case No. 2:22-cv-01419-CDS-DJA, and I have personal knowledge of the facts offered herein;
2. I joined Plaintiff's law firm on July 17, 2023. Since that time, I was been actively getting familiarized with the facts and procedural postures of the respective case load assigned to me;
3. One of those cases was the instant matter, styled as Escobar v. United States. It is my understanding that there were active settlement discussions between the United States and former counsel for Plaintiff;
4. I have been in contact with counsel for the United States, Stephen Hanson, regarding the current posture of settlement discussions, and I have been actively attempting to contact and convey the offer to Plaintiff in an attempt to determine whether this matter may be resolved;
5. Therefore, the parties respectfully request an additional thirty (30) day extension to the deadline to file the Joint Pre-Trial Order, until September 7, 2023.
6. That I make this Declaration under penalty of perjury and attest to the truth of all matters stated herein.
For the foregoing reasons, the parties stipulate to extend the deadline for the joint pretrial order to September 7, 2023.
IT IS SO ORDERED.