Opinion
2:15-CV-01572-APG-DJA
11-10-2022
VICTOR PEREZ, as Special Administrator of the Estate of CARLOS PEREZ, deceased; VICTOR PEREZ, as the Guardian Ad Litem for SOPHIA ELISE PEREZ, a minor; VICTOR PEREZ, as the Guardian Ad Litem for ALEXANDER ISRYAL PEREZ, a minor; and MYRA PEREZ, individually, Plaintiff, v. STATE OF NEVADA; 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 1-X, inclusive; and ROES 1-X, inclusive, Defendants.
STIPULATION AND ORDER TO EXTEND DEADLINE FOR SUBMISSION OF JOINT PRETRIAL ORDER
(THIRD 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 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., hereby respectfully submit this Stipulation and Order Extending the Deadline for Submission of Joint Pretrial Order currently due on November 10, 2022 an additional thirty (30) days, up to and including December 12, 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.] Hence, this is the third request for an extension.
This stipulated request for an extension is made in good faith and not for the purposes of delay. Counsel for Defendant Jeff Castro is currently out of the jurisdiction through November 11, 2022 and will be traveling on the week of November 14, 2022 for an oral argument before the United States Court of Appeals for the Ninth Circuit. Counsel for Defendants State of Nevada ex rel Nevada Department of Corrections, James Greg Cox, Timothy Filson, Dwight W. Neven and Ronald Oliver also require additional time due to recent changes in representation, as former counsel Steven Shevorski, Esq. and Akke Levin, Esq. are no longer with the Attorney General's office. Further, current senior counsel for Defendants State of Nevada ex rel Nevada Department of Corrections, James Greg Cox, Timothy Filson, Dwight W. Neven and Ronald Oliver is currently the Attorney General's point person for election litigation and is therefore unable to review and provide additions to the joint pretrial order before the current November 10, 2022 deadline.
WHEREFORE the parties stipulate that the time for parties to submit the joint pretrial order be extended an additional thirty (3) days, up to and including December 12, 2022.
IT IS SO-ORDERED: