Opinion
Case No. 2:18-cv-02191-JAD-BNW
03-30-2020
AARON D. FORD Attorney General HENRY H. KIM (Bar No. 14390) Deputy Attorney General State of Nevada Office of the Attorney General 555 E. Washington Ave., Ste. 3900 Las Vegas, Nevada 89101 (702) 486-3095 (phone) (702) 486-3773 (fax) Email: hkim@ag.nv.gov Attorneys for Defendants James Dzurenda, Bob Faulkner, Martin Naughton, and Frances Oakman
AARON D. FORD
Attorney General
HENRY H. KIM (Bar No. 14390)
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., Ste. 3900
Las Vegas, Nevada 89101
(702) 486-3095 (phone)
(702) 486-3773 (fax)
Email: hkim@ag.nv.gov Attorneys for Defendants
James Dzurenda, Bob Faulkner,
Martin Naughton, and Frances Oakman Order Granting
MOTION FOR EXTENSION OF TIME TO SUBMIT PROPOSED STIPULATION TO DISMISS (FIRST REQUEST)
Defendants, James Dzurenda, Bob Faulkner, Martin Naughton, and Frances Oakman, by and through counsel, Aaron D. Ford, Attorney General for the State of Nevada, and Henry H. Kim, Deputy Attorney General, hereby file this Motion for Extension of Time to Submit Proposed Stipulation to Dismiss pursuant to this Court's Minute Order (ECF No. 18).
I. INTRODUCTION
On February 28, 2020, parties reached a settlement at the Early Mediation Conference. (ECF No. 18). The Court ordered that proposed stipulation to dismiss be submitted by March 30, 2020. (ECF No. 18). Defense counsel sent out to Patterson a proposed settlement agreement as well as a stipulation and order for dismissal. Patterson responded with a letter proposing several changes to the terms of the settlement agreement. Parties have not yet finalized the terms of the settlement agreement.
II. ARGUMENT
Defense counsel has been working diligently to finalize the terms of the settlement agreement with Patterson. Accordingly, Defendants respectfully request that this Court grant additional 45 days to submit a proposed stipulation to dismiss so that parties can finalize the terms of the settlement agreement.
III. CONCLUSION
For the foregoing reasons, Defendants respectfully request that this Court grant additional 45 days to submit a proposed stipulation and order of dismissal. With the 45-day extension, the proposed stipulation and order of dismissal would be due May 14, 2020.
DATED this 30th day of March, 2020.
Respectfully submitted,
AARON D. FORD
Attorney General
By: /s/ Henry H. Kim
HENRY H. KIM (Bar No. 14390)
Deputy Attorney General
Attorneys for Defendants
ORDER
Good cause appearing, IT IS HEREBY ORDERED that the motion to extend time [ECF No. 20] is GRANTED. The parties have until May 14, 2020, to submit their proposed stipulation and order of dismissal.
/s/_________
U.S. District Judge 3-30-2020