Opinion
2:21-cv-01505-APG-EJY
11-30-2022
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.
KEMP & KEMP James P. Kemp, NV Bar No. 6375 Attorney for Plaintiff HONE LAW Jill Garcia, NV Bar No. 7805 Attorneys for Defendants
KEMP & KEMP James P. Kemp, NV Bar No. 6375 Attorney for Plaintiff
HONE LAW Jill Garcia, NV Bar No. 7805 Attorneys for Defendants
STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT [FIRST REQUEST]
Pursuant to LR IA 6-1 and LR 26-3, 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 extend time for Plaintiff to Respond to Defendants' Motion for Summary Judgment (ECF No. 40) from the current deadline of November 30, 2022 through and including January 9, 2023 . This is the first request for an extension of this specific deadline. The requested extension is sought in good faith and not for purposes of undue delay. The reasons for the extension are as follows:
1. Pursuant to the court's order there is one more deposition to be taken of the FRCP Rule 30(b)(6) representative of Nevada Family Care and Wellness, the practice of one of Plaintiff's doctors (Dr. Fakhouri). Due to scheduling problems this deposition has been reset to December 9, 2022. In order to have time to have the deposition transcribed and distributed, given the time of the year with the holidays in full swing, it would be reasonable to extend the deadline for the Summary Judgment response until one month after the deposition takes place.
2. Additionally, Plaintiff's counsel will be out of the country on a long planned family commitment from December 17, 2022 through January 4, 2023.
Accordingly, additional time after the transcript from the final deposition is obtained and to account for the holidays is reasonable and the extension to January 9, 2023 should be sufficient.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.