1 || AARON D. FORD Attorney General 2 || DAVID A. BAILEY, Bar No. 13661 Deputy Attorney General 3 State of Nevada 100 N. Carson Street 4 || Carson City, Nevada 89701-4717 Tel: (775) 684-1163 5 E-mail: [email protected] 6 || Attorneys for Defendants under 7 Limited Notice of Appearance

8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 || FELIPE P. LAZOS, JR.., Case No. 3:22-cv-00099-RCJ-CLB 11 Plaintiff, DEFENDANTS’ MOTION FOR 12 EXTENSION OF TIME [SECOND REQUEST] 13 || ERIN PARKS, et al., 14 Defendant. 15 Defendants Michael Minev and Erin Parks, by and through counsel, Aaron D. Ford, 16 || Attorney General of the State of Nevada, and David A. Bailey, Deputy Attorney General, 17 || hereby request this Court to extend Defendants’ deadline to respond to Plaintiff Felipe 18 || Lazos, Jr.'s Emergency Motion (ECF No. 3). This motion is based on Federal Rule of Civil 19 || Procedure 6(b)(1)(A), LR 1A 6-1, the following Memorandum of Points and Authorities, and 20 || all papers and pleadings on file in this case, and such other and further information as this 21 || Court may deem appropriate to consider. 22 MEMORANDUM OF POINTS AND AUTHORITIES 23 RELEVANT FACTS AND PROCEDURAL HISTORY 24 This is a pro se prisoner civil rights action brought by inmate Plaintiff Filipe Lazos, 25 || Jr. 67232), currently housed at Lovelock Correctional Center, asserting claims arising 26 || under

. ECF No. 8. Following judicial screening under 42 U.S.C. § 1915A, 27 Court allowed one claim to proceed alleging deliberate indifference to a serious medical 28 ||need. ECF No. 7 at 6.

ARGUMENT 2 Courts have inherent powers to control their dockets, see Ready Transp., Inc. v. AAR 3 || Mfg, Inc.,

(citations omitted), and to “achieve the orderly and expeditious 4 || disposition of cases.” Chambers v. NASCO, Inc.,

(1991). “Such power is 5 |{indispensable to the court’s ability to enforce its orders, manage its docket, and regulate 6 ||}insubordinate... conduct.” See Wallace v. U.S.A.A. Life General Agency, Inc.,

(D. Nev. Sept. 30, 2010) (citing Mazzeo v. Gibbons, No. 2:08-cv013887—RLH-— 8 |}PAL,

, at *2 (D.Nev. 2010)). LR IA 6-1 discusses requests for 9 |/continuances. The rule states: 10 (a) A motion or stipulation to extend time must state the reasons for the extension requested and must inform the court of all 11 previous extensions of the subject deadline the court granted. (Examples: “This is the first stipulation for extension of time to 12 file motions.” “This is the third motion to extend time to take discovery.”) 13 14 This is the second request to extend this deadline and is requested for good cause. 15 || Defendants’ research into Plaintiff's claims has revealed that Lazos saw the appropriate 16 || provider on May 2, 2022 and he is in the process of being scheduled for surgery. 17 || Undersigned counsel requests a second short extension to confirm the date of the 18 || anticipated surgery. Defendants, therefore, request a seven-day extension of time to 19 respond to Plaintiff's Emergency Motion. 20 This request for an additional week to respond will not hinder Lazos’s prosecution of 21 || his case, especially because he is receiving his requested relief. Defendants assert that the 22 ||requisite good cause is present to warrant the requested extension of time, and that this 23 || request is made in good faith and not for the purpose of delay. 24 DATED this 20th day of May 2022. 25 No further extensions of time AARON % FORD 26 will be granted. ormney Wenera By: /s/ David A. Bailey 27 |S OO oon oD DAVID A. BAILEY, Bar No. 13661 ay £9 Deputy Attorney General 28 » Attorneys for Defendant

LTINIITCM CTADV OCC AAAMICTDOATOEK IWINGC

1 CERTIFICATE OF SERVICE 2 I certify that Iam an employee of the Office of the Attorney General, State of Nevada 3 that on this 20th day of May, 2022, I caused to be served a copy of the foregoing, 4 || DEFENDANTS’ MOTION FOR EXTENSION OF TIME [SECOND REQUEST], U.S. 5 || District Court CM/ECF Electronic Filing to: 6 Felipe P. Lazos, Jr., #67232 7 1200 Prison Road

3 Lovelock, Nevada 89419-5110

9 /s/ Karen Kaston An employee of the 10 Office of the Attorney General 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28