Opinion
2:15-cv-01572-APG-DJA
12-12-2022
VICTOR PEREZ, as Special Administrator of the Estate of CARLOS PEREZ, deceased; VICTOR PEREZ, as Guardian Ad Litem for S.E.P., a minor; VICTOR PEREZ, as Guardian 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.
AARON D. FORD Attorney General Craig Newby (Bar. No. 8591) Chief Litigation Counsel Kiel B. Ireland (Bar No. 15368) Deputy Solicitor General Office of the Attorney General 100 N. Carson St. Attorneys for Defendants State of Nevada, James “Greg” Cox, Timothy Filson, Dwight Neven, and Ronald Oliver LEWIS, BRISBOIS, BISGAARD, & SMITH, LLP Robert W. Freeman, Esq. Attorneys for Defendant Raynaldo-John Ramos MARQUIS & AURBACH Craig R. Anderson, Esq. Attorney for Defendant Jeff Castro CLARK HILL, PLLC Paola M. Armeni (Bar No. 8357) Attorneys for Plaintiffs ASHCRAFT & BARR, LLP Jeffrey F. Barr, Esq. Alina M. Shell Attorneys for Defendant Isaiah Smith
AARON D. FORD Attorney General
Craig Newby (Bar. No. 8591) Chief Litigation Counsel
Kiel B. Ireland (Bar No. 15368) Deputy Solicitor General
Office of the Attorney General 100 N. Carson St.
Attorneys for Defendants State of Nevada, James “Greg” Cox, Timothy Filson, Dwight Neven, and Ronald Oliver
LEWIS, BRISBOIS, BISGAARD, & SMITH, LLP
Robert W. Freeman, Esq. Attorneys for Defendant Raynaldo-John Ramos
MARQUIS & AURBACH Craig R. Anderson, Esq. Attorney for Defendant Jeff Castro
CLARK HILL, PLLC Paola M. Armeni (Bar No. 8357) Attorneys for Plaintiffs
ASHCRAFT & BARR, LLP Jeffrey F. Barr, Esq. Alina M. Shell Attorneys for Defendant Isaiah Smith
STIPULATION AND ORDER TO EXTEND DEADLINE FOR SUBMISSION OF JOINT PRETRIAL
ORDER (FOURTH REQUEST)
Pursuant to LR IA 6-1, 6-2 and LR 26-4, Defendant Isaiah Smith, by and through his counsel of record Jeffrey F. Barr, Esq. and Alina M. Shell of the law firm of Armstrong Teasdale LLP; Plaintiff Victor Perez, as Special Administrator of the Estate of Carlos Perez, deceased, by and through his counsel, Paola M. Armeni, Esq., of the law firm of Clark Hill; 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, Kiel B. Ireland, Esq., of the Attorney General's Office; Defendant Raynaldo Ramos, by and through his counsel, Robert W. Freeman, Jr. Esq., of the law firm of Lewis Brisbois Bisgaard & Smith, LLP; and Defendant Jeff Castro, by and through his counsel, Craig R. Anderson, Esq., of the law firm of Marquis Aurbach Chtd, submit this Stipulation and Order Extending the Deadline for Submission of Joint Pretrial Order currently due on December 12, 2022 an additional 14 days. Because December 26, 2022 is a federal holiday, the new deadline would be December 27, 2022.
This Court previously denied a joint unopposed motion to extend the deadline for submission of the Joint Pretrial Order on September 19, 2022, and then granted a modified version of the same request. ECF No. 221, 223. It then granted another stipulated extension. ECF No. 227. Hence, this is the fourth request for an extension.
This stipulated request for an extension is made in good faith and not for the purposes of delay. All parties have been diligently working on their portions of the joint pretrial order and have completed their respective sections. However, the parties need a short extension to integrate the different proposals and complete a joint pretrial order that all parties can agree to. This joint pretrial order is more complicated than most because the parties must navigate the conflicting factual and legal positions of five sets of separately represented parties.
WHEREFORE the parties stipulate that the time for parties to submit the joint pretrial order be extended an additional 14 days, up to and including December 27, 2022.
IT IS SO ORDERED.