United States District Court, D. Nevada
ARTHUR JULIUS-GREEN BERAHA fka TRAVERS A. GREEN, Plaintiff,
STATE OF NEVADA, et al., Defendants.
D. FORD Attorney General
M. BRADY, Attorneys for Defendants
DEFENDANTS' MOTION FOR EXTENSION OF TIME TO FILE
SUMMARY JUDGMENT MOTION (FIRST REQUEST)
Renee Baker, James Dzurenda, William Gittere, and William
Reubart, by and through counsel Aaron D. Ford, Attorney
General of the State of Nevada, and Katlyn M. Brady, Deputy
Attorney General, requests this Court grant a thirty (30) day
extension of time to file a summary judgment motion.
Court should grant Defendants' motion for an extension of
time to file a summary judgment motion. On November 19, 2019,
undersigned counsel was assigned to represent the Defendants
in this matter because the previous Deputy Attorney General
unexpectedly left the Office of the Nevada Attorney General.
Further, due to the Thanksgiving holiday, undersigned counsel
will be unable to complete a review of the record and prepare
a summary judgment motion before the deadline of December 2,
January 18, 2018, Plaintiff filed the First Amended
Complaint, ECF No. 10. On June 15, 2018, this Court filed its
screening order. ECF No. 12. This Court allowed the following
claims to proceed:
• Count I alleging a due process violation and a
statutory violation against former Director Dzurenda. ECF No.
12 at 12:14-17.
• Count II, alleging free exercise, FLUIPA, and equal
protection violations against former Director Dzurenda,
former Warden Filson, and Bryen. Id. at 12:18-19.
• Count III, alleging federal telecommunication
violations against Century Link, EPSI, and ICS. Further,
Count III alleged a violation of Nevada's Deceptive Trade
Practices Act against Century Link, EPSI and ICS.
Id. at 12:21-24.
3, 2019, this Court entered its scheduling order. ECF No. 87.
The original deadline for dispositive motions was October 2,
2019. ECF No. 87 at 3:27-27 - 4:1.
September 26, 2019, Plaintiff filed the Second Amended
Complaint. ECF No. 105. Plaintiff alleged the following
• Count I alleged a due process violation and statutory
violation claim against former Director Dzurenda, in his
official capacity only. Id. at 2-4.
• Count II alleged religious claims against former
Director Dzurenda, William Gittere, and William Reubart.
Id. at 5-7.
• Count III alleged religious claims regarding the ALEPH
Institute against former Director Dzurenda and ...