London v. Daniels

1 |} AARON D. FORD Attorney General |} LAURA M. GINN (Bar No. 8085) Deputy Attorney General || State of Nevada N. Carson Street || Carson City, NV 89701-4717 Tel: (775) 684-1120 || E-mail: [email protected] || Attorneys for Defendants Skyler Sheeks and Luis Sencion-Gonzalez 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA || EDWARD LONDON, Case No. 3:20-cv-00284-MMD-CLB 11 Plaintiff, 12 MOTION FOR EXTENSION OF TIME TO FILE A MOTION FOR || CHARLES DANIELS, et al., SUMMARY JUDGMENT [FIRST REQUEST] 14 Defendants 15 Defendants Skyler Sheeks and Luis Sencion-Gonzalez (collectively, NDOC || Employees), by and through counsel Aaron D. Ford, Attorney General for the State of || Nevada, and Laura M. Ginn, Deputy Attorney General, hereby move this Court for an || extension of time file a Motion for Summary Judgment. This Motion is made and based ||upon Federal Rule of Civil Procedure 6(b)(1)(A), the attached Points and Authorities, the || papers, and pleadings on file herein, and such other and further information as this Court 21 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, 48 (1991) Such power is ||indispensable to the court’s ability to enforce its orders, manage its docket, and regulate ||insubordinate conduct. Jd. (See also Mazzeo v. Gibbons, No. 2:08-cv—01387—RLH-—PAL, 28 WL 3910072, at *2 (D.Nev. 2010)).

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

6 This is the first request, filed timely, and is requested for good cause. The parties ||engaged in a meet and confer on April 14, 2022 to discuss Defendant Sheeks’ Requests for || Admission and Interrogatories propounded on London. London was given an extension to |icomplete the Requests for Admission and Interrogatories on or before April 19, 2022.

10 || NDOC Employees filed a Motion to Compel (ECF No. 26) requesting this Court to order || London to respond to the Interrogatories and deem the Requests for Admission admitted.

12 || London has not responded to NDOC Employees Motion to Compel yet. NDOC Employees || respectfully request an extension to allow this Court to rule on the Motion to Compel and || London to respond.

15 NDOC Employees provide the following information in accordance with Local Rule || 26-3. London failed to respond to Defendant Sheeks’ Interrogatories and failed to respond || to the Requests for Admission. Discovery closed on April 4, 2022.

18 The proposed deadlines are: 19 Dispositive motion deadline: July 7, 2022 20 Joint pretrial order (if no dispositive motions filed): August 8, 20221 21 Counsel submits that the recent Motion to Compel and outstanding discovery in this || case constitutes good cause for granting this extension of time to file a Motion for Summary || Judgment.

28 1 The date was adjusted to a weekday.

1 Therefore, Defendants request this Court to extend the deadline from May 4, 2022, 2 July 7, 2022, to file a Motion for Summary Judgment.

3 DATED this 27th day of April, 2022.

4 AARON D. FORD 5 Attorney General By: /s/ Laura M. Ginn 6 LAURA M. GINN (Bar No. 8085) 7 Deputy Attorney General 3 Attorneys for Defendant 10 IT IS SO ORDERED. i Dated: April 27, 2022 12 * 14 UNITED STATES,MAGISTRATE JUDGE 1 CERTIFICATE OF SERVICE 2 I certify that I am an employee of the State of Nevada, Office of the Attorney ||General, and that on April 27, 2022, I electronically filed the foregoing, MOTION FOR || EXTENSION OF TIME TO FILE A MOTION FOR SUMMARY JUDGMENT [FIRST || REQUEST], via this Court’s electronic filing system. Parties who are registered with this ||Court’s electronic filing system will be served electronically. For those parties not ||registered, service was made by depositing a copy for mailing in the United States Mail, || first-class postage prepaid, at Carson City, Nevada, addressed to the following: 9 Edward London, #1170368 10 pouthern Desert Correctional Center u Indian Springs, NV 89070 13 An employee ofthe 14 Office of the Nevada Attorney General