Opinion
3:17-cv-00303-MMD-CBC
01-10-2022
MARK MANIBUSAN, Plaintiff, v. NEVADA DEPARTMENT OF CORRECTIONS, et al., Defendants
Matthew J. Rashbrook Robert L. Langford & Associates Attorneys for Plaintiff John C. Dorame Attorneys for NDOC Defendants
Matthew J. Rashbrook Robert L. Langford & Associates Attorneys for Plaintiff
John C. Dorame Attorneys for NDOC Defendants
STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTION DEADLINE (THIRD REQUEST)
Pursuant to Local Rule 26-4, Plaintiff Mark Manibusan, by and through his counsel, Robert L. Langford, Esq., and Matthew J. Rashbrook, and Defendants Renee Baker, Dwayne Baze, Tara Carpenter, James G. Cox, James Dzurenda, and Ronda Larsen (the "NDOC Defendants"), by and through their counsel, Aaron D. Ford, Nevada Attorney General, and John C. Dorame, Deputy Attorney General, respectfully submit the following Stipulation and Order to Extend the Dispositive Motion deadline. This Stipulation is the third request for such an extension, and is entered by the parties in good faith and not for the purpose of delay.
DISCOVERY COMPLETED
. Plaintiffs Initial Disclosures
. Defendants Initial Disclosures
. Plaintiff s Interrogatories to Defendants
. Plaintiffs Request for Production of Documents to NDOC Defendants
. Plaintiff s Request for Admission to NDOC Defendants
DISCOVERY REMAINING
No additional discovery is needed in this matter. The remaining case management deadlines are:
Dispositive motion deadline: January 10, 2022
Joint pretrial order (if no dispositive motions filed): March 2, 2022
REASONS DEADLINE HAS NOT BEEN SATISFIED
1. During the previous deadline period, counsel for Plaintiff Mark Manibusan has been absent from the office caring for his spouse while she suffered an illness which required hospitalization. This has caused a significant drop in productivity and the undersigned is unable to comply with the present deadline.
2. As indicated in the previous request for an extension of this deadline (ECF. 67), counsel for defendants was assigned this matter on or about November 8, 2021. At or around the same time, current counsel inherited a No. of other matters from prior counsel, all with nearly concurrent significant deadlines. Counsel has endeavored to comply with these all, but in order to have an adequate opportunity to become familiar with the facts and circumstances, as well as the legal arguments presented in this matter, counsel requires further time.
PROPOSED SCHEDULE
The parties propose that the following current deadlines be extended by 30 days:
1. The current deadline for dispositive motions is January 10, 2021. The Parties stipulate that deadline be extended to February 9. 2022.
2. The parties must file a Joint Pretrial Order no later than March 2, 2022. The parties stipulate that deadline be extended to April 1, 2022. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be suspended until thirty (30) days after a decision on the dispositive motions, or further order of the Court.
For the foregoing reasons, Mr. Manibusan and the NDOC Defendants hereby stipulate to the above extensions.
IT IS SO STIPULATED.
ORDER
Based on the foregoing stipulation, the deadline for dispositve motions and joint pretrial order shall be extended as described.
IT IS SO ORDERED.