Opinion
2:19-cv-01273-RFB-EJY
04-04-2023
KIRSTIN BLAISE LOBATO, Plaintiff, v. LAS VEGAS METROPOLITAN POLICE DEPARTMENT, NEVADA, THOMAS THOWSEN, and JAMES LAROCHELLE, Defendants.
Luke Busby Designated Resident Nevada Counsel for Plaintiff Kirstin Blaise Lobato Elizabeth Wang Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato Megan Pierce Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato Craig Anderson Kathleen Wilde Marquis Aurbach Coffing Counsel for Defendants David B. Owens Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato
Luke Busby Designated Resident Nevada Counsel for Plaintiff Kirstin Blaise Lobato
Elizabeth Wang Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato
Megan Pierce Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato
Craig Anderson Kathleen Wilde Marquis Aurbach Coffing Counsel for Defendants
David B. Owens Loevy & Loevy Counsel for Plaintiff Kirstin Blaise Lobato
Richard F. Boulware, II Judge
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE REPLY IN SUPPORT OF PLAINTIFF'S MOTION FOR LEAVE TO FILE AN AMENDED COMPLAINT (ECF NO. 95)
(First Request)
Elayna J. Youchah Magistrate Judge
Pursuant to Local Rule IA 6-1, the parties, by and through their counsel of record, hereby agree and stipulate that the time for Plaintiff to file her reply in support of her Motion for Leave to File an Amended Complaint (ECF No. 95), which was filed on March 1, 2023, should be extended by one week-from April 7, until and including April 14, 2023. The following grounds constitute good cause:
1. On March 1, 2023, Plaintiff filed a Motion for Leave to File an Amended Complaint (ECF No. 95). Pursuant to Local Rule 7-2(b), Defendants' response was due on March 15, 2023.
2. On March 6, 2023, Defendants filed a stipulation extending the deadline to file their response from March 15, 2023 to March 31, 2023 (ECF No. 96).
3. While Plaintiff's counsel have endeavored to finish the reply by the current deadline of April 7, 2023, they are occupied with other time-sensitive matters, including Ms. Lobato's brief for the interlocutory appeal pending in the Ninth Circuit - which is due on April 5, 2023 - along with an appellate brief in Apolo-Albino v. State of Washington and a reply brief in Simmers v. King County, both due on April 6, 2023.
4. This stipulation is not brought for any improper purpose, but rather to ensure that both sides to this matter are permitted the benefit of appropriate review of relevant evidence and the time to clearly and adequately lay out the issues for the Court's resolution.
5. Plaintiff's counsel have conferred with counsel for Defendants, and the parties have agreed to this extension. Accordingly, Plaintiff and Defendants stipulate that Plaintiff's deadline to file her reply in support of her Motion for Leave to File an Amended Complaint should be extended until April 14, 2023. This stipulation is made in good faith and not for the purpose of delay.
ORDER
IT IS SO ORDERED that the above Stipulation is hereby GRANTED. Plaintiff shall have until April 14, 2023, to file her reply in support of her Motion for Leave to File an Amended Complaint.