Opinion
2:20-cv-01761-CDS-BNW
04-21-2023
LaTesha Watson, Plaintiff v. City of Henderson, et al., Defendants
COOK & KELESIS, LTD. Julie L. Sanpei Marc P. Cook, (NV Bar No. 4574) Attorneys for Plaintiff Latesha Watson SNELL & WILMER, LLP Christian P. Ogata Patrick G. Byrne (NV Bar No. 7636) Julie L. Sanpei (NX7 Bar No. 5479) Richard C. Gordon (NV Bar No. 9036) Paul Swenson Prior (NV Bar No. 9324) Christian P. Ogata (NV Bar No. 15612) 3883 Howard Hughes Parkway, Suite 1100 Attorneys for Defendant City of Henderson CLARK HILL PLLC Nicholas M. Wieczorek, Esq. Attorneys for Defendant Kevin Abernathy
COOK & KELESIS, LTD.
Julie L. Sanpei
Marc P. Cook, (NV Bar No. 4574)
Attorneys for Plaintiff Latesha Watson
SNELL & WILMER, LLP
Christian P. Ogata
Patrick G. Byrne (NV Bar No. 7636)
Julie L. Sanpei (NX7 Bar No. 5479)
Richard C. Gordon (NV Bar No. 9036)
Paul Swenson Prior (NV Bar No. 9324)
Christian P. Ogata (NV Bar No. 15612) 3883
Howard Hughes Parkway, Suite 1100
Attorneys for Defendant City of Henderson
CLARK HILL PLLC
Nicholas M. Wieczorek, Esq.
Attorneys for Defendant Kevin Abernathy
STIPULATION AND PROPOSED ORDER EXTENDING DEADLINES FOR REPLIES TO MOTIONS FOR SUMMARY JUDGMENT AND FOR CITY OF HENDERSON TO FILE ANSWER TO FIRST AMENDED COMPLAINT
Defendants City of Henderson (the “City”), Kevin Abernathy, and plaintiff LaTesha Watson (collectively the “Parties”) stipulate to extend the deadline for the Parties' to file their replies in support of the motions for summary judgment up to and including May 12, 2023, and for the City to file its answer to the first amended complaint up to and including April 27, 2023. The Parties make the following stipulation for good cause, not for the purpose of delay, and for the following reasons:
1. On November 1, 2021, Watson amended her complaint, asserting nine causes of action against the City, Abernathy, and several previously named individual defendants.
2. During discovery, Watson voluntarily dismissed five of those defendants and another after it had closed.
3. On February 16, 2023, Judge Weksler granted the Parties' stipulation to extend the dispositive motion deadline to February 22, 2023.
ECF No. 155.
4. Watson then filed two motions for partial summary judgment: one against the Cityand one against Abernathy.
ECF No. 157.
ECF No. 158.
1. The City and Abernathy both also filed motions for summary judgment.
ECF Nos. 162, 164.
2. On March 23, 2023, this Court found that resolution of the motions to dismiss was unnecessary given the filing of the cross-motions for summary judgment.
ECF No. 183.
5. After the motions for summary judgment were filed, Judge Weksler granted Abernathy's motion to compel additional deposition testimony from Watson. That deposition took place on March 23, 2023, and the transcript for that deposition became available April 2, 2023.
6. This Court previously granted an extension for the briefing deadlines, setting the responses for April 14, 2023, and the replies for May 5, 2023.
7. All Parties filed their responses to the pending summary judgment motions.
8. Given the number of claims still at issue in this dispute and on which the Parties have moved for summary judgment, and the complex legal issues involved within each, the Parties need additional time to complete their replies to the motions.
9. And because the Parties are currently finalizing briefing related to the summaryjudgment motions, the City needs additional time to prepare its answer to Watson's complaint, which requires it to analyze the allegations that survive Watson's voluntary dismissal of various defendants in this matter.
10. The Parties have agreed to the extensions requested.
11. This stipulation is made in good faith and not for the purpose of delay.
Therefore, the Parties respectfully request au extension for the Parties to file then replies hr support of the motions for summary judgment up to and including May 12, 2023, and for the City to file its answer to Watson's first amended complaint up to and including April 27, 2023.
ORDER
Good cause appearing, IT IS HEREBY ORDERED that the parties' stipulation is GRANTED.
• Replies supporting the motions for summary judgment [ECF Nos. 157, 158, 162, 164] are due on May 12, 2023.
• The City's answer to Watson's first amended complaint is due on April 27, 2023.
IT IS SO ORDERED.