Opinion
2:17-cv-01121-APG-EJY
10-30-2023
LAUSTEVEION JOHNSON, Plaintiff, v. DAVID WILLIS, et al., Defendants.
FRANK M. FLANSBURG III, ESQ., Nevada Bar No. 6974 fflansburg@bhfs.com EMILY A. ELLIS, ESQ., Nevada Bar No. 11956 eellis@bhfs.com MALIQ I. KENDRICKS, ESQ., Nevada Bar No. 15254 mkendricks@bhfs.com JAMIE P. LEAVITT, ESQ., Nevada Bar No. 16268 jleavitt@bhfs.com BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for Plaintiff Lausteveion Johnson
FRANK M. FLANSBURG III, ESQ., Nevada Bar No. 6974 fflansburg@bhfs.com
EMILY A. ELLIS, ESQ., Nevada Bar No. 11956 eellis@bhfs.com
MALIQ I. KENDRICKS, ESQ., Nevada Bar No. 15254 mkendricks@bhfs.com
JAMIE P. LEAVITT, ESQ., Nevada Bar No. 16268 jleavitt@bhfs.com
BROWNSTEIN HYATT FARBER SCHRECK, LLP
Attorneys for Plaintiff Lausteveion Johnson
STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT (THIRD REQUEST)
Plaintiff Lausteveion Johnson (“Plaintiff”), by and through his counsel of record of the law firm Brownstein Hyatt Farber Schreck, LLP, and Defendants Rashonda Smith and Douglas Thrasher (“Defendants,” and together with Plaintiff, the “Parties”), by and through their counsel of record of the State of Nevada, Office of the Attorney General, hereby stipulate and agree, contingent on this Court's approval, as follows:
1. This stipulation is made pursuant to LR IA 6-1.
2. On July 11, 2023, Defendants filed their Motion for Summary Judgment (“Defendants' Motion”). See ECF No. 174.
3. Plaintiff's response to Defendants' Motion was originally due on August 1, 2023.
4. On July 21, 2023, this Court granted the Parties' Stipulation and Order to Extend Time for Plaintiff to Respond to Defendants' Motion for Summary Judgment (First Request), extending the deadline for Plaintiff to file a response to Defendants' Motion until fourteen (14) days after the conclusion on any unsuccessful global settlement conference or mediation. See ECF No. 176.
5. Following a failed settlement conference, on October 19, 2023, this Court granted the Parties' Stipulation and Order to Extend Time for Plaintiff to Respond to Defendants' Motion for Summary Judgment (Second Request), extending the deadline to October 26, 2023. See ECF No. 181.
6. Plaintiff's counsel was notified on October 25, 2023, that Plaintiff was taken into custody on October 12, 2023 for a parole violation, which has impacted Plaintiff's counsel's ability to meaningfully consult with Plaintiff regarding his response to Defendants' Motion.
7. The parties have agreed to an additional two-week extension for Plaintiff to submit his response to Defendants' Motion, which would make the deadline to file a response November 9, 2023.
8. This is the third request for an extension of this deadline.
9. This stipulation is made in good faith and is not made in an attempt to delay proceedings.
IT IS SO STIPULATED.
IT IS SO ORDERED.