Attorney General 2 Christopher M. Guy (Bar No. 15239) Deputy Attorney General 3 State of Nevada Office of the Attorney General 4 555 East Washington Avenue Suite 3900 5 Las Vegas, Nevada 89101 (702) 486-3326 (phone) 6 (702) 486-3773 (fax) Email: [email protected] 7 Attorneys for Defendants 8 Brian Williams, Isidro Baca, Megan Sullivan, Daron Franklin, 9 Lisa Walsh, James Cox, James Dzurenda, Dwight Neven, Romeo 10 Aranas, Gregory Bryan, Jennifer Nash, Laurie Hoover, and Sheryl

LISA A. RASMUSSEN, Esq. Law Offices of Kristina Wildeveld & Associates 13 550 E. Charleston Blvd. Las Vegas, NV 89101 14 T. (702) 222-0007 | F. (702) 222-0001 www.veldlaw.com 15 Attorneys for Plaintiff 16 17 UNITED STATES DISTRICT COURT 18 DISTRICT OF NEVADA 19 KARISMA GARCIA, Case No. 2:17-cv-00359-APG-VCF 20 Plaintiff, 21 vs. JOINT MOTION TO EXTEND 22 STATE OF NEVADA, et al., DISPOSTIVE MOTION DEADLINE (FOURTH REQUEST) 23 Defendants. 24 25 That the Parties, hereby move to extend the time to complete dispositive motions 26 from April 1, 2021 until June 1, 2021. 27 /// 28 /// 2 A. Discovery Completed pursuant to Local Rule 26-31 3 To date, Garcia disclosed all of the documents in her possession on July 6, 2020. 4 Defendants disclosed all of the documents in its possession on August 11, 2020. Defendants 5 provided Garcia with a PDF of all prison medical files on January 26, 2021. Garcia provided 6 a first supplement to her initial disclosures on March 1, 2021. 7 B. Reasons that Dispositive Motions Cannot be Completed within 8 the Date Set by Scheduling Order 9 Defendants’ counsel is currently preparing for an emergency appeal in one of the two 10 preliminary injunction cases he defended in March. In addition to the unexpected appeal, 11 counsel faces several dispositive deadlines between March 29th and April 12th. Counsel is 12 also required to take a mandatory furlough day April 5th. Unfortunately, an immediate 13 family of Defendants’ counsel passed away this month after contracting COVID-19. 14 Counsel will be on bereavement leave the week of April 19th. 15 Under the circumstances the Parties have agreed to a 60-day extension. 16 17 18 /// 19 /// 20 /// 21 1 LR 26-3. EXTENSION OF SCHEDULED DEADLINES: A motion or stipulation to extend any date set by the discovery plan, scheduling order, or 22 other order must, in addition to satisfying the requirements of LR IA 6-1, be supported by a showing of good cause for the extension. A motion or stipulation to extend a deadline set 23 forth in a discovery plan must be received by the court no later than 21 days before the expiration of the subject deadline. A request made within 21 days of the subject deadline 24 must be supported by a showing of good cause. A request made after the expiration of the subject deadline will not be granted unless the movant also demonstrates that the failure 25 to act was the result of excusable neglect. A motion or stipulation to extend a discovery deadline or to reopen discovery must include: 26 (a) A statement specifying the discovery completed; (b) A specific description of the discovery that remains to be completed; 27 (c)The reasons why the deadline was not satisfied or the remaining discovery was not completed within the time limits set by the discovery plan; and 28 (d) A proposed schedule for completing all remaining discovery. 2 There is no remaining discovery, and the Parties do not anticipate 3 circumstances that would warrant a request to reopen discovery. 4 D. Proposed Schedule 5 • Dispositive Motion Deadline June 1, 2021 6 • Joint Pretrial Order Deadline July 1, 20212 7 II. GOOD CAUSE EXISTS TO EXTEND PENDING DEADLINES3 8 Under LR 26-3, a request made within 21 days of the subject deadline must be 9 supported by a showing of good cause. Good cause is not a rigorous or high standard, and 10 courts have construed the test broadly. Ahanchion v. Xenon Pictures, Inc.,

, 11 1259 (9th Cir. 2010). Rule 6(b) “[is] to be liberally construed to effectuate the general 12 purpose of seeing that cases are tried on the merits.” Rodgers v. Watt,

, 459 13 (9th Cir. 1983); Wong v. Regents of the Univ. of Calif.,

(9th Cir. 2005) 14 (“Of course, courts should not mindlessly enforce deadlines.”). In general, an application 15 for extension of time under Rule 6(b)(1)(A) will be granted in the absence of bad faith. 16 Ahanchion,

(quoting 4B Charles Alan Wright & Arthur R. Miller, Federal 17 Practice and Procedure § 1165 (3d ed. 2004)) (internal quotations omitted). 18 As stated above, several reasons exist that led the Parties to agree to a 60-day 19 extension. Defendants’ counsel could not reasonably anticipate two preliminary 20 injunctions, emergency litigation, and the death of an immediate family member. Under 21 the above circumstances, the Parties agree that good cause exists. 22 /// 23 2 LR 26-1(b)(5): Unless the discovery plan otherwise provides and the court so orders, the deadline 24 for the joint pretrial order is 30 days after the dispositive-motion deadline. If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 25 days after decision on the dispositive motions or further court order 3 Rule 6(b), Fed. R. Civ. Proc. 26 Rule 6(b)(1), Fed. R. Civ. Pro., governs extensions of time: When an act may or must be done within a specified time, the court may, for good 27 cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires; or (B) on motion made after the 28 time has expired if the party failed to act because of excusable neglect. 1 CONCLUSION 2 Based upon the foregoing reasons, the Parties request that this Court grant the 3 ||requested relief and continue deadlines as requested herein. 4 5 Dated 30th day of March 2021. Dated 30th day of March 2021. 6 By: /s/Lisa A.Rasmussen . By: /s/ Christopher M. Guy 7 Lisa A. Rasmussen, Esq. Christopher M. Guy, Esq. Law Offices of Kristina Wildeveld & Deputy Attorney General 8 Associates Office of the Nevada Attorney General 550 E. Charleston Blvd. 555 E. Washington Avenue, #3900 9 Las Vegas, NV 89101 Las Vegas, Nevada 89101 10 www.veldlaw.com Attorneys for Defendants Attorneys for Plaintiff 11 12 13 IT IS SO ORDERED 14 Loa ioc. 17 UNITED STATES MAGISTRATE JUDGE 18 March 31, 2021 19 20 21 22 23 24 25 26 27 28