Opinion
2:22-cv-00592-RFB-EJY
11-07-2022
JEREMY JOHN HALGAT, an individual, Plaintiffs, v. UNITED STATES OF AMERICA, DAVID N. KARPEL, individually, DOES 1 through 100; and ROES 1 through 100; inclusive, Defendants.
LEWIS BRISBOIS BISGAARD & SMITH LLP ROBERT FREEMAN E. MATTHEW FREEMAN Attorneys for Defendant Las Vegas Metropolitan Police Department MELANIE HILL LAW PLLC MELANIE A. HILL Attorneys for Plaintiff Jeremy John Halgat
LEWIS BRISBOIS BISGAARD & SMITH LLP
ROBERT FREEMAN
E. MATTHEW FREEMAN
Attorneys for Defendant Las Vegas Metropolitan Police Department
MELANIE HILL LAW PLLC
MELANIE A. HILL
Attorneys for Plaintiff Jeremy John Halgat
STIPULATION TO EXTEND DEADLINE TO RESPOND TO LVMPD'S MOTION TO DISMISS AND JOINDER [ECF NOS. 37 AND 38]
(FIRST REQUEST)
RICHARD F. BOULWARE, II., UNITED STATES DISTRICT JUDGE.
NOW COMES the Plaintiff, JEREMY HALGAT (“Plaintiff”), by and through his attorneys, Melanie A. Hill and Melanie Hill Law PLLC, and Defendant, LAS VEGAS METROPOLITAN POLICE DEPARTMENT (“LVMPD”), by and through its attorney Robert Freeman, who hereby stipulate that the deadline for Plaintiff to respond to Defendant LVMPD Motions to Dismiss and Joinder [ECF Nos. 37 and 38] be extended pursuant to Local Rule IA 6-1.
This is the first request for an extension of the deadlines. In support of this Stipulation and Request, the parties state as follows:
1. Defendant LVMPD filed their Motions to Dismiss on October 21, 2022 [ECF Nos. 37 and 38].
2. Plaintiff's deadline to respond to the Motions to Dismiss is November 4, 2022.
3. Counsel for Halgat and the United States have conferred to attempt to resolve counsel for Plaintiffs' request to be added to the Protective Order in place in the underlying criminal case so that Plaintiff may share the criminal discovery with undersigned counsel. The discovery is necessary to further plead the complaint in this case in response to arguments made in the currently pending motions.
4. Counsel for Plaintiff has also conferred with the local U.S. Attorneys' office regarding the same. Counsel have determined that a motion will be necessary to allow counsel for Plaintiff to be added to the Protective Order in the underlying criminal case so that discovery may be reviewed by counsel for Plaintiff and used to further plead the complaint in this case. It is also undersigned counsel's understanding that the United States has no objection to Plaintiff's counsel being added to the protective order upon further motion and order of this court.
5. To allow this motion to be filed and allow counsel to review the underlying criminal discovery for purposes of prosecuting this civil case and further respond to the pending Motions to Dismiss, the parties have stipulated to extend Plaintiff's response deadline to December 6, 2022. The parties have further stipulated to allow Defendants USA and Karpel until January 6, 2023 to file their responses to Plaintiff's filing.
6. This Request for an extension of time is not sought for any improper purpose or other purpose of delay. Rather, it is sought by the parties solely to allow sufficient time to allow Plaintiff's counsel to be added to the protective Order in the underlying criminal case, review the criminal discovery, and respond to the LVMPD's Motion to Dismiss and Joinder.
WHEREFORE, the parties respectfully request that the Court extend the deadlines as stipulated to herein.
ORDER
IT IS SO ORDERED.