1 || AARON D. FORD Attorney General 2 || MEREDITH N. BERESFORD, Bar No. 13308 Deputy Attorney General 3 || State of Nevada Public Safety Division 4 || 100 N. Carson Street Carson City, NV 89701-4717 5 || Tel: (775) 684-1120 E-mail: [email protected] 6 Attorneys for Defendants 7 || Adam Brendel, Jayson Brumfield, John Keast, Kathryn Reynolds and Thomas Wyatt 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 |} SEAN DAVID FOLLETT, Case No. 3:19-cv-00154-MMD-CLB 12 Plaintiff, 13 || vs. MOTION TO EXTEND DEADLINE TO FIL ANSWER TO AUGUST 25, 2020 14 || JAMES DZURENDA, et al., 15 Defendants. 16 Defendants, Adam Brendel, Jayson Brumfield, John Keast, Kathryn Reynolds and Thom 17 || Wyatt, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Mered: 18 || N. Beresford, Deputy Attorney General, hereby files this Motion for Extension of Deadline to F 19 || Answer to August 25, 2020. This motion is based on Federal Rule of Civil Procedure 6(b)(1)(A), t 20 || following Memorandum of Points and Authorities, and all papers and pleadings on file in this action. 2] MEMORANDUM OF POINTS AND AUTHORITIES 22 I. ARGUMENT 23 Defendants respectfully request an extension of time to August 25, 2020 to file an Answ 24 || Counsel for Defendants has already drafted portions of the Answer but Counsel for Defendants hac 25 || death in her immediate family and has been out of state. Counsel did email Plaintiff's Counsel 26 || inform her of this request. Further, this request has been necessitated by recent quarantine measut 27 || imposed in response to the COVID-19 virus pandemic. Namely, Governor Sisolak issued a “stay 28 || home” directive on April 1, 2020, whereby Deputy Attorneys General and other staff are required tc

1 |) utilized home-based working arrangements. As a result, the already limited staff ate the Office of t 2 || Attorney General is rendered less efficient due to constraints imposed by limited Virtual Prive 3 || Networks (VPN) and lack of remote document access. 4 Federal Rule of Civil Procedure 6(b)(1) governs extensions of time and provides as follows: 5 || When an act may or must be done within a specified time, the court may, for good cause, extend t 6 || time: (A) with or without motion or notice fi the court acts, or if a request is made, before the origir 7 || time or its extension expires; or (B) on motion made after the time has expired if the party failed to < 8 || because of excusable neglect. 9 The requested extension of time should afford Defendants adequate time to finish preparing a 10 || file the Answer. 11 For these reasons, Defendants respectfully request a one week extension of time from t 12 || current deadline to file an Answer in this case, with a new deadline to and including Tuesday, Augt 13 |] 25, 2020. 14 Proposed Schedule for Deadline 15 Answer deadline August 25, 2020 16 DATED this 17th day of August, 2020. 17 AARON D. FORD 8 Attorney General By: /s/ Meredith N. Beresford 19 MEREDITH N. BERESFORD, Bar No. 13308 Deputy Attorney General Attorneys for Defendants

22 IT IS SO ORDERED. 23 Dated: August 17, 2020. 24 .

2%6 UNITED STA STRATE JUDGE 27 28

1 CERTIFICATE OF SERVICE 2 I certify that I am an employee of the Office of the Attorney General, State of Nevada, and tk 3 || on this 17th day of August, 2020, I caused to be served a copy of the foregoing, MOTION T 4 || EXTEND DEADLINE TO FILE ANSWER TO AUGUST 25, 2020, by U.S. District Cot 5 || CM/ECF Electronic Filing on: 6 || Emily A. Buchwald, Esq., Bar No. 13442 Pisanelli Bice PLLC 7 ||

" Street, Suite 300 Las Vegas, NV 89101 8 || [email protected] 9 10 11 __/s/ Perla M. Hernandez An employee of the 12 Office of the Attorney General 13 14 15 16 17 18 19 20 2] 22 23 24 25 26 27 28