Opinion
2:19-cv-00969-GMN-VCF
08-23-2023
AMBER FOSTER, Plaintiff, v. STATE OF NEVADA, et al., Defendants.
GALLIAN WELKER & ASSOCIATES, LC Travis N. Barrick, Esq. (#9257) Nathan E. Lawrence, Esq. (#15060) Attorneys for Plaintiff AARON D. FORD Attorney General LORIN M. TAYLOR (Bar No. 14958) Deputy Attorney General VICTORIA C. COREY (Bar No. 116364C) Deputy Attorney General DOUGLAS R. RANDS (Bar No. 3572) Senior Deputy Attorney General State of Nevada Office of the Attorney General Attorneys for Defendants Harold Wickham, Dwight Neven, And Richard Ashcraft THE VIEIRA FIRM Andrea L. Vieira, Esq. (#15667) Attorneys for Plaintiff.
GALLIAN WELKER & ASSOCIATES, LC
Travis N. Barrick, Esq. (#9257)
Nathan E. Lawrence, Esq. (#15060)
Attorneys for Plaintiff
AARON D. FORD Attorney General
LORIN M. TAYLOR (Bar No. 14958) Deputy Attorney General
VICTORIA C. COREY (Bar No. 116364C) Deputy Attorney General
DOUGLAS R. RANDS (Bar No. 3572) Senior Deputy Attorney General State of Nevada Office of the Attorney General
Attorneys for Defendants Harold Wickham, Dwight Neven, And Richard Ashcraft
THE VIEIRA FIRM
Andrea L. Vieira, Esq. (#15667)
Attorneys for Plaintiff.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE TRIAL DATE
Pursuant to LR 7-1, LR IA 6-1 and 6-2, the parties, by and through their respective counsel of record, stipulate and request that this Court continue the trial date in this matter, which is currently set for September 25, 2023. (ECF No. 64.) This stipulation serves as the parties' second request to continue the trial date. This request is made in good faith and is not intended for purposes of delay. The parties do not intend to request additional extensions to re-open discovery or further delay trial upon this stipulation's approval by the Court.
Parties stipulated to continue this trial previously due to a court conflict, as the Honorable Judge Navarro was scheduled to be in the midst a six-week trial at that time.
On August 18, 2023, Defendants' counsel was informed that Deputy Director Harold Wickham, a defendant in this matter, will be out of the country from September 14, 2023, until October 4, 2023, for a vacation that has been planned for over a year. On August 21, 2023, Defendants' counsel reached out to Plaintiff's counsel to discuss continuing the trial date. Plaintiff's counsel agreed to move the trial date, so long as the Court agrees. It is in the parties' best interest to continue the trial date to ensure the trial runs as efficiently as possible and to allow Deputy Director Harold Wickham to attend trial and testify as originally planned, as he is a named defendant in this matter.
Upon the Court's request, Defendants are willing to provide a declaration from Deputy Director Wickham regarding his vacation and information regarding the scheduling of his vacation.
For these reasons the parties jointly offer the following three trial dates:
January 8, 2024
January 15, 2024
January 22, 2024
The parties further stipulate that they be excused from their appearances at the Master Trial Scheduling Conference set for September 5, 2023, at 10:00 AM, (ECF. No. 66). It is expressly understood by the undersigned that the Court will set the trial of this matter on one of the agreed-upon dates if possible. If not, the trial will be set at the convenience of the Court's calendar after such dates. The parties estimate that the trial will take a total of 3-5 court days.
IT IS SO STIPULATED.
ORDER
IT IS HEREBY ORDERED that the trial in this case is continued and re-set for jury trial on a fixed / stacked calendar on January 22, 2024 at 8;30 a.m. Calendar call will be held at January 16, 2024 at 9:00 a.m.
IT IS SO ORDERED.