Opinion
2:15-cv-01572-APG-DJA
12-16-2022
VICTOR PEREZ, as Special Administrator of the Estate of CARLOS PEREZ, deceased; VICTOR PEREZ, as the Guardia Ad Litem for S.E.P., a minor; VICTOR PEREZ, as the Guardia Ad Litem for A.I.P., a minor, Plaintiffs, v. STATE OF NEVADA, ex.rel. NEVADA DEPARTMENT OF CORRECTIONS; DIRECTOR GREG COX, individually; WARDEN DWIGHT NEVEN, individually; ASSISTANT WARDEN TIMOTHY FILSON, individually; COT. RAMOS, individually; LIEUTENANT OLIVER, individually; CORRECTIONS OFFICER CASTRO, individually; CORRECTIONS OFFICER SMITH, individually; and DOES I-X, inclusive; and ROES I-X, inclusive, Defendants.
CLARK HILL, PLLC Paola M. Armeni, Esq. Gia N. Marina, Esq. Attorneys for Plaintiffs, Perez Family MARQUIS AURBACH Craig R. Anderson, Esq. Attorneys for Defendant Castro ARMSTRONG TEASDALE Jeffrey F. Barr, Esq. Alina Shell, Esq. Attorneys for Defendant Isaiah Smith LEWIS BRISBOIS BISGAARD & SMITH LLP Robert W Freeman, Jr., Esq. Attorneys for Defendant Ramos OFFICE OF THE ATTORNEY GENERAL Craig Newby, Esq. Attorneys for Defendants, State of Nevada, Dwight W. Neven, James Greg Cox Ronald Oliver, Timothy Filson
CLARK HILL, PLLC
Paola M. Armeni, Esq.
Gia N. Marina, Esq.
Attorneys for Plaintiffs, Perez Family
MARQUIS AURBACH
Craig R. Anderson, Esq.
Attorneys for Defendant Castro
ARMSTRONG TEASDALE
Jeffrey F. Barr, Esq.
Alina Shell, Esq.
Attorneys for Defendant Isaiah Smith
LEWIS BRISBOIS BISGAARD & SMITH LLP
Robert W Freeman, Jr., Esq.
Attorneys for Defendant Ramos
OFFICE OF THE ATTORNEY GENERAL
Craig Newby, Esq.
Attorneys for Defendants, State of Nevada, Dwight W. Neven, James Greg Cox Ronald Oliver, Timothy Filson
STIPULATION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFFS TO FILE A REPLY TO NDOC DEFENDANTS' RESPONSE TO PEREZ FAMILY'S MOTION TO RECONSIDER ORDER GRANTING DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' FOURTEENTH AMENDMENT LOSS OF FAMILIAL ASSOCIATION CLAIM
Victor Perez, as Special Administrator of the Estate of Carlos Perez, deceased, by and through his counsel, Paola M. Armeni, Esq., and Gia N. Marina, Esq., the law firm of Clark Hill, Defendant Raynaldo Ramos, by and through his counsel, Robert W. Freeman, Jr. Esq., the law firm of Lewis Brisbois Bisgaard & Smith, LLP, Defendants, State of Nevada ex rel Nevada Department of Corrections, James Greg Cox, Timothy Filson, Dwight W. Neven and Ronald Oliver, by and through their counsel, Craig Newby, Esq. and Kiel Ireland, Esq., the Attorney General's Office, Defendant Isaiah Smith, by and through his counsel of record, Jeffrey F. Barr, Esq., and Alina Shell, Esq. of the law firm of Armstrong Teasdale, and Defendant Jeff Castro, by and through his counsel, Craig R. Anderson, Esq., of the law firm of Marquis Aurbach, hereby respectfully submit this Stipulation and Order Extending Time for Plaintiff to reply to NDOC Defendants' Response to Perez Family's Motion to Reconsider Order Granting Defendants' Motion for Summary Judgment on Plaintiffs' Fourteenth Amendment Loss of Familial Association Claim [Dkt 232] filed on December 12, 2022, which the response is currently due on December 19, 2022, to be extended an additional eight (8) days up to and including December 27, 2022.
Although Plaintiffs' counsel has begun working on replying to Defendant's Response, counsel requires a brief extension to complete the Reply. This request for extension is made in good faith and not for the purposes of delay.
WHEREFORE, the parties stipulate that the time for Plaintiffs to file their reply to NDOC Defendants' Response to Perez Family's Motion to Reconsider Order Granting Defendants' Motion for Summary Judgment on Plaintiffs' Fourteenth Amendment Loss of Familial Association Claim [Dkt 232], be extended an additional eight (8) days up to and including December 27, 2022.
APPROVED AS TO FORM AND CONTENT.
ORDER
IT IS SO ORDERED.