Olsen v. Nevada Department of Corrections

Attorney General DOUGLAS R. RANDS, Bar No. 3572 Senior Deputy Attorney General State of Nevada N. Carson Street Carson City, Nevada 89701-4717 Tel: (775) 684-1150 E-mail: [email protected] Attorneys for Defendants Romeo Aranas, Rusty Donnelly and Jonathan Perry 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA CARL OLSEN, Case No. 3:18-cv-00149-MMD-CLB 11 Plaintiff, v. MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S NEVADA DEPARTMENT MOTION TO COMPEL DISCOVERY OF CORRECTIONS, et al., (ECF NO. 43) Defendants 16 Defendant, Romeo Aranas, Rusty Donnelly and Jonathan Perry, by and through counsel Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, move this Court for an extension of time to respond to Plaintiff’s Motion to Compel the Production of Documents (ECF No. 43). 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.

22 MEMORANDUM OF POINTS AND AUTHORITIES 23 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)).

28 LR IA 6-1 discusses requests for continuances. The rule states: 1 (a) A motion or stipulation to extend time must state the reasons for the extension 2 requested and must inform the court of all previous extensions of the subject 3 deadline the court granted. (Examples: “This is the first stipulation for extension 4 of time to file motions.” “This is the third motion to extend time to take 5 discovery.”)

6 This is the first request, and is requested for good cause. Counsel is currently scheduled to || begin a jury trial in front of District Judge Jones in the matter of Sales v. Adamson, Case Number || 3:17-cv-00186-RCJ-WGC to begin August 24, 2021. Counsel has been preparing for that trial, and || has not been able to complete the response to this motion. This trial preparation has made it difficult || to research and file the response to the motion in a timely manner. Additionally, the responses to || the requests have been sent to Plaintiff. (Exhibit 1 and 2). Therefore, there will be no prejudice to || Plaintiff. There were additional issues in the motion that require coordination with the prison at || Lovelock Correctional Center. Counsel has been unable to complete the coordination at this time.

14 || Therefore, a short extension of time is requested.

15 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 September 2, 2021.

17 DATED this 23rd day of August, 2021.

18 AARON D. FORD Attorney General 20 By: /s/ Douglas R. Rands DOUGLAS R. RANDS, Bar No. 3572 21 Senior Deputy Attorney General 22 Attorneys for Defendant 24 IT IS SO ORDERED.

25 Dated: 24, 2021 .

27 UNITED STATESMAGISTRATE JUDGE 1 CERTIFICATE OF SERVICE 2 I certify that I am an employee of the Office of the Attorney General, State of Nevada, and || that on this 23rd day of August, 2021, I caused a copy of the foregoing, MOTION FOR || EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S MOTION TO COMPEL || DISCOVERY (ECF NO. 42), to be served, by U.S. District Court CM/ECF Electronic Filing on the || following: || Carl Olsen, #31147 Lovelock Correctional Center || 1200 Prison Road Lovelock, NV 89419 10 FOU MWD 6 Sa __ An employee of the Office 11 of the Attorney General