Opinion
2:18-CV-01911-APG-EJY
02-08-2023
ROSEN MARIANO, an individual, Plaintiff, v. THE CITY OF LAS VEGAS, a political subdivision of the State of Nevada; CORRECTIONAL HEALTHCARE COMPANIES, INC., a foreign corporation; CORRECT CARE SOLUTIONS, LLC, a foreign limited liability company; MICHELE FREEMAN, Chief of Detention Enforcement for the City of Las Vegas; CORRECTION OFFICER DOE 1-10; HEALTHCARE WORKER DOES 11-20; DOES 21-99; inclusive; ROE CORPORATIONS 100-199, inclusive, Defendants.
DENNIS M. PRINCE Nevada Bar No. 5092 ANDREW R. BROWN Nevada Bar No. 15875 PRINCE LAW GROUP KEITH E. GALLIHER, JR Nevada Bar No. 220 THE GALLIHER LAW FIRM Attorneys for Plaintiff Rosen Mariano
DENNIS M. PRINCE
Nevada Bar No. 5092
ANDREW R. BROWN
Nevada Bar No. 15875
PRINCE LAW GROUP
KEITH E. GALLIHER, JR
Nevada Bar No. 220
THE GALLIHER LAW FIRM
Attorneys for Plaintiff Rosen Mariano
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE PLAINTIFF ROSEN MARIANO'S RESPONSE TO DEFENDANT CORRECT CARE SOLUTIONS, LLC'S RENEWED MOTION FOR SUMMARY JUDGMENT
(First Request)
IT IS HEREBY STIPULATED AND AGREED, between the Parties, by and through their respective counsel of record, that the deadline for Plaintiff Rosen Mariano to file his response to Defendant Correct Care Solutions, LLC's Renewed Motion for Summary Judgment (ECF No. 92) will be extended ten (10) days from February 10, 2023 to February 20, 2023. The Motion was filed on January 20, 2023. Defendant Correct Care Solutions, LLC's reply in support of the Motion will also be extended ten (10) days from February 24, 2023 to March 6, 2023. This is the Parties' first request to extend time. This Stipulation and [Proposed] Order is submitted in accordance LR IA 6-1.
The Parties respectfully request this brief extension of time to accommodate Plaintiff's counsel. Specifically, Mr. Prince and Mr. Brown have multiple depositions and pleading deadlines arising before the original deadline to file Plaintiff's response to the Motion. The requested extension of time will allow Plaintiff to comprehensively address the issues raised in the Motion. The Parties' requested extension is not made in bad faith or to unnecessarily delay these proceedings. Therefore, the Parties respectfully request the Court approve the foregoing stipulation.
ORDER
IT IS SO ORDERED.