Casteel v. Aranas

Attorney General DOUGLAS R. RANDS, Bar No. 3572 Senior Deputy Attorney General State of Nevada N. Carson Street Carson City, NV 89701-4717 Tel: (775) 684-1150 E-mail: [email protected] Attorneys for Defendants Romeo Aranas, John Borrowman and Michael Minev 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA SCOTT CASTEEL, Case No. 3:20-cv-00381-GMN-CLB 12 Plaintiff, MOTION FOR EXTENSION OF TIME vs. (ECF NO. 85) ROMEO ARANAS, et al., 15 Defendants.

16 Defendants, Romeo Aranas, John Borrowman and Michael Minev, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, hereby move this Court for an extension of time to respond to Plaintiff’s Motion for extension of time to file a motion to amend. (ECF No. 79). This Court Ordered, by ECF No. 85, Defendants Counsel to respond to the Motion by July 20, 2021. Counsel is scheduled to be out of state that week on a pre-planned family vacation. Therefore, the Defendants respectfully request the Court extend the deadline by 10 days, to July 30, 2021. This request is made and based on the attached points and authorities, the papers and pleadings on file herein, and such other and further information as this Court may deem appropriate.

25 MEMORANDUM OF POINTS AND AUTHORITIES 26 Courts have inherent powers to control their dockets, see Ready Transp., Inc. v. AAR Mfg, Inc., 627 F.3d 402, 404 (citations omitted), and to “achieve the orderly and expeditious disposition of cases.” Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991) “Such power is indispensable to the || court’s ability to enforce its orders, manage its docket, and regulate insubordinate [] conduct. Id. || (citing Mazzeo v. Gibbons, No. 2:08-cv01387—RLH-PAL, 2010 WL 3910072, at *2 (D.Nev. 2010)).

3 || LRIA 6-1 discusses requests for continuances. The rule states: 4 (a) A motion or stipulation to extend time must state the reasons for the extension requested and must inform the court of all previous extensions of the subject 5 deadline the court granted. (Examples: “This is the first stipulation for extension of time to file motions.” “This is the third motion to extend time to take discovery.”)

7 This is the first request, and is requested for good cause. Counsel is currently scheduled to || be out of state on a pre-planned family vacation during the week of July 19, 2021. Therefore, it will || be difficult to research and file the response in this timeframe. There will be no prejudice to Plaintiff || because if his motion is granted, deadlines for discovery and motion practice will need to be || revisited.

12 Therefore, it is requested that the Defendant have an additional 10 days to file their response to || Plaintiff's motion, which would then be due on July 30, 2021.

14 DATED this 15th day of July, 2021.

15 AARON D. FORD Attorney General 17 By: /s/ Douglas R. Rands DOUGLAS R. RANDS, Bar No. 3572 18 Deputy Attorney General 19 Attorneys for Defendants 21 IT IS SO ORDERED.

22 Dated: July 15, 2021 95 UNITED STATES NAGISTRATE JUDGE

2 I certify that I am an employee of the Office of the Attorney General, State of Nevada and that on this 15th day of July, 2021, I caused a copy of the foregoing, MOTION FOR EXTENSION OF TIME (ECF NO. 85), to be served, by U.S. District Court CM/ECF Electronic Filing on the following: Scott Casteel, #82403 Care of ESP Law Librarian Ely State Prison P.O. Box 1989 Ely, NV 89301 [email protected] 11 __/s/ Roberta W. Bibee__________ An employee of the Office of the Attorney General