Opinion
2:21-cv-01505-APG-EJY
10-11-2022
DONAVAN McINTOSH, Plaintiff, v. CITY OF NORTH LAS VEGAS, a Municipal Corporation and political subdivision of the State of Nevada; PAMELA OJEDA in her official and/or individual capacities; CLINTON RYAN in his official and/or individual capacities; ALEJANDRO RODRIGUEZ in his official and/or individual capacities; DOES I-X, Defendants.
HONE LAW Jill Garcia, NV Bar No. 7805 Eric D. Hone, NV Bar No. 8499 Attorneys for Defendants KEMP & KEMP, ATTORNEYS AT LAW James P. Kemp, NV Bar No. 6375 Attorneys for Plaintiff
HONE LAW
Jill Garcia, NV Bar No. 7805
Eric D. Hone, NV Bar No. 8499
Attorneys for Defendants
KEMP & KEMP, ATTORNEYS AT LAW
James P. Kemp, NV Bar No. 6375
Attorneys for Plaintiff
[PROPOSED] STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTION DEADLINE AND BRIEFING SCHEDULE
[FIRST REQUEST]
Pursuant to LR IA 6-1, LR 7-2(b), LR 26-3, and FRCP 56(b), Defendants City of North Las Vegas, Pamela Ojeda, Clinton Ryan, and Alejandro Rodriguez (“Defendants”) and Plaintiff Donavan McIntosh (“Plaintiff'), by and through their undersigned counsel, hereby stipulate to amend the operative Discovery Plan and Scheduling Order (ECF No. 27) to extend the dispositive motion deadline by one week from October 7, 2022, to October 14, 2022.
This is the parties' first requested extension to the dispositive motion deadline. The requested extension is sought in good faith and not for purposes of undue delay. Good cause exists to extend the dispositive motion deadline. The reason for the requested extension is that Defendants prepared and intended to file a motion for summary judgment on October 7, 2022, and just learned that a declarant is unexpectedly unavailable to execute a declaration to be submitted in support of said motion. The parties stipulate to a brief one-week extension to the dispositive motion deadline to enable the said declarant sufficient time to execute the intended declaration in support of the motion.
PROPOSED REVISED DISCOVERY PLAN AND SCHEDULING ORDER
1. Dispositive Motions Deadline
The parties shall file any dispositive motions by no later than October 14, 2022. Oppositions to any dispositive motions shall be filed by no later than November 30, 2022.Replies in support of any dispositive motions shall be filed by no later than December 14, 2022.
The parties request an extension as to this deadline due to Plaintiff's counsel's trial and hearing schedule, as well as in consideration of the Thanksgiving holiday.
2. Joint Pretrial Order Deadline
If no dispositive motions are filed, and unless otherwise ordered by this Court, the Joint Pretrial Order shall be filed 30 days after the date set for filing dispositive motions, and therefore, not later than November 14, 2022. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be suspended until 60 days after the Court enters a ruling on the dispositive motions or otherwise by further order of the Court.
STIPULATION
Accordingly, the parties stipulate, subject to approval of this Court, to the following new proposed deadlines:
Deadline
Current Deadline
Revised Deadline
Dispositive Motions
October 7, 2022
October 14, 2022
Opposition to Dispositive
Motions October 28, 2022
November 30, 2022
Replies to Dispositive Motions
November 11, 2022
December 14, 2022
Joint Pretrial Order
November 7, 2022
November 14, 2022
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.