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Perez v. State

United States District Court, D. Nevada

January 10, 2017

VICTOR PEREZ, as Special Administrator of the Estate of CARLOS PEREZ, deceased; VICTOR PEREZ, as the Guardian Ad Litem for S.E.P., a minor; VICTOR PEREZ, as the Guardian Ad Litem for A.I.P, 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 I-X, inclusive; and ROES I-X, inclusive, Defendants.

          POTTER LAW OFFICES CAL J. POTTER, III, ESQ. Nevada Bar No. 1988 C. J. POTTER, IV, ESQ. Attorneys for Plaintiffs

          OFFICE OF THE NEVADA ATTORNEY GENERAL ADAM P. LAXALT, ATTORNEY GENERAL STEVE SHEVORISKI HEAD OF COMPLEX LITIGATION Nevada Bar No. 8256 THERESA M. HAAR DEPUTY ATTORNEY GENERAL Attorneys for NDOC Defendants

          LEWIS BRISBOIS BISGAARD & SMITH Robert W. Freeman, Jr., Esq. ROBERT W. FREEMAN, JR., ESQ. Attorney for Defendant Correction Officer Trainee Raynaldo-John Ramos

          MARQUIS AURBACH COFFING Craig R. Anderson, Esq. CRAIG R. ANDERSON, ESQ. Attorney for Defendant Castro

          ASHCRAFT & BARR, LLP Jeffrey F.Barr, Esq. JEFFREY F. BARR, ESQ. LEE I. IGOLDY, ESQ. Attorneys for Defendant Isaiah Smith

          STIPULATION AND ORDER TO EXTEND PLAINTIFFS' REPLY TO NDOC DEFENDANTS' MOTION TO DISMISS AMENDED COMPLAINT [ECF 90] AND EXTEND DEFENDANTS' REPLY TO PLAINTIFFS' OPPOSITION TO NDOC DEFENDANTS' MOTION TO DISMISS AMENDED COMPLAINT [First Request]

         Plaintiffs, named above, by and through their counsel of record Cal J. Potter, III, Esq. and C. J. Potter, IV, Esq. of Potter Law Offices; Defendants, NDOC, James “Greg” Cox, Timothy Filson, Dwight Neven, and Ronald Oliver (hereinafter “NDOC Defendants”) by and through their counsel of record Steve Shevorski and Theresa M. Haar, Deputy Attorney Generals, COT. Ramos, by and through his counsel of record, Robert W. Freeman, Jr. Esq. of Lewis Brisbois Bisgaard & Smith, LLP; Defendant, CO Castro, by and through his counsel of record, Craig R. Anderson, Esq. of Marquis Aurbach Coffing; and Defendant CO Smith, by and through his counsel of record, Jeffrey R. Barr, Esq. of Ashcroft & Barr, LLP, and hereby submit this Stipulation to Extend Plaintiffs' Reply to NDOC Defendants' Motion to Dismiss Amended Complaint [ECF 90], filed December 28, 2016, currently due January 11, 2017, be extended an additional twenty-one (21) days up to and including Wednesday, February 1, 2017, and NDOC Defendants' Reply to Plaintiffs' Opposition to NDOC Defendants' Motion to Dismiss Amended Complaint be due on Wednesday, February 22, 2017.

         Although Plaintiffs' counsel has been actively working on responding to Defendants' Motion, Plaintiffs' counsel has been unable to complete the Response. Since the filing of Defendants' Motion to Dismiss Plaintiffs' Amended Complaint, Plaintiffs' counsel has had a Supreme Court Brief and a Ninth Circuit Brief due, three (3) depositions, numerous substantive motions and responses; as well as other general appearances and deadlines. This request for extension is made in good faith and not for the purposes of delay.

         WHEREFORE, the parties respectfully request that Plaintiffs' Response to Defendants' Motion to Dismiss Plaintiffs' Amended Complaint, be extended an additional twenty-one (21) days up to and including Wednesday, February 1, 2017, and NDOC Defendants' Reply to Plaintiffs' Opposition to NDOC Defendants' Motion to Dismiss Amended Complaint be due on Wednesday, February 22, 2017.

         APPROVED AS TO FORM AND CONTENT.

         SO ORDERED.


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