Perez v. Neven

1 Rene L. Valladares Federal Public Defender Nevada State Bar No. 11479 *Amelia L. Bizzaro Assistant Federal Public Defender Wisconsin State Bar No. 1045709 E. Bonneville Ave., Ste. 250 Las Vegas, Nevada 89101 (702) 388-6577 [email protected] *Attorney for Petitioner Gladys Perez

UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA Gladys Perez, 13 Petitioner, Case No. 2:14-cv-02087-APG-BNW 14 v. Joint Stipulation Dwight Neven, Warden, et al., ORDER 16 Respondents.

1 Petitioner Gladys Perez, by Assistant Federal Public Defender Amelia L.

2|| Bizzaro, and Respondents Dwight Neven, et al.., by Deputy Attorney General 3|| Jessica Perlick, file this Joint Stipulation following the February 28, 2020, hearing and this Court’s March 2, 2020 Order. Counsel met and conferred by telephone on 5|| March 4, 2020 and propose the following schedule: 6 1. Discovery in this case must be completed by April 6, 2020.

7 2. The Petitioner must file and serve a memorandum of points and 8 authorities addressing only the equitable tolling issue, and, as 9 confirmed at the February 28th hearing, the relation back issue as it 10 relates to the Ninth Circuit’s recent en banc decision in Ross v. 11 Williams, __ F.8d __, 2020 WL 878518 (Feb. 24, 2020) by May 6, 2020.

12 3. The Respondents may file a response memorandum within 14 days 18 after service of Perez’s memorandum.

14 4, This Court will reinstate the Respondent’s Motion to Dismiss (ECF No. 15 34) and the Petitioners’ Motion for Evidentiary Hearing (ECF No. 111) 16 and issue a comprehensive ruling.

17 Dated March 5, 2020.

Respectfully submitted, 20 Rene L. Valladares Aaron D. Ford Federal Public Defender Attorney General 22 /s/ Amelia L. Bizzaro /s/ Jessica Perlick 93 Amelia L. Bizzaro Jessica Perlick Assistant Federal Public Defender Senior Deputy Attorney General 24 Counsel for Michael L. Baker Counsel for Renee Baker, et al.

IT IS SO ORDERED.

27 UNITED STATES DISTRICT JUDGE Dated: March 5, 2020.