Richards v. Cox

Attorney General WILLIAM SHOGREN, Bar No. 14619 Deputy Attorney General AUSTIN T. BARNUM, Bar No. 15174 Senior Deputy Attorney General State of Nevada Office of the Attorney General 555 E. Washington Avenue, Suite 3900 Las Vegas, Nevada 89101 Tel: (702) 486-0661 E-mail: [email protected] [email protected] Attorneys for Defendants Renee Baker, Eric Boardman and James Cox Richard Schonfeld, Nevada Bar No. 6815 [email protected] CHESNOFF & SCHONFELD South Fourth Street, 2nd Floor Las Vegas, Nevada 89101 Telephone: (702) 384-5563 John Burton, Pro Hac Vice, California Bar No. 86029 [email protected] THE LAW OFFICES OF JOHN BURTON North Fair Oaks Avenue Pasadena, California 91103 Telephone: (626) 449-8300 Attorneys for Plaintiff Stacey M. Richards

19 UNITED STATES DISTRICT COURT 20 DISTRICT OF NEVADA STACEY M. RICHARDS, Case No. 2:16-cv-01794-JCM-BNW 22 Plaintiff, JOINT STIPULATION AND ORDER v. TO VACATE AND RESCHEDULE THE SETTLEMENT CONFERENCE GREG COX, et al., 25 Defendants.

26 Defendants, Renee Baker, Eric Boardman, and James “Greg” Cox, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, Austin T. Barnum, Senior Deputy Attorney General, and William P. Shogren, Deputy Attorney General, and Schonfeld, Esq., hereby submit this Joint Stipulation and Order to Vacate and Reschedule the Settlement conference current set for June 24, 2022, to a date most convenient for this Court in early August 2022.

5 MEMORANDUM OF POINTS AND AUTHORITIES I. RELEVANT BACKGROUND 7 This Court issued an order scheduling a settlement conference on June 24, 2022.

8 ECF No. 103. Confidential settlement statements are due June 16, 2022. Id. at 1:13-17.

9 Parties held a meet and confer on May 24, 2022, to discuss, among other things, the current date. One of the undersigned counsel for defendants, Senior Deputy Attorney General, Austin T. Barnum, recently received mandatory military orders for the United States Army Reserves that prevent his attendance at the settlement conference on June 24, 2022. Although Plaintiff is prepared to proceed with the settlement conference on the date notice, to accommodate Defendants, he agreed to filing this joint stipulation for an order vacating the current date and deadlines for the settlement conference. The next most appropriate timeframe for both Parties is in the first week of August. (Plaintiff’s counsel John Burton has a three-week jury trial scheduled to commence in Los Angeles Superior Court on July 5, 2022.)

19 II. LEGAL DISCUSSION 20 Parties stipulate to this Court vacating the current order setting the settlement conference and rescheduling for a date most convenient to this Court in early August.

22 Courts have the inherent power to control their dockets. Hamilton Copper & Steel Corp. v. Primary Steel, Inc., 898 F.2d 1428, 1429 (9th Cir. 1990) (citations omitted). Parties make this request because one of the undersigned counsel for Defendants recently received military orders and is, therefore, unavailable for the current date. This request is made in good faith and is not for the purpose of causing delay.

1 CONCLUSION 2 Parties stipulate to this Court vacating its order in ECF No. 103 and rescheduling || the settlement conference for a date most convenient to this Court in early August 2022.

4 || DATED this 27 day of May 2022. DATED this 27 day of May 2022.

5 AARON D. FORD 6 Attorney General || By: __/s/ John Burton By: __/s/ Austin T. Barnum Richard Schonfeld, Nevada Bar No. 6815 Austin T. Barnum, Bar No. 15174 || [email protected] Senior Deputy Attorney General CHESNOFF & SCHONFELD William Shogren, Bar No. 14619 11520 South Fourth Street, □□ Floor Deputy Attorney General Las Vegas, Nevada 89101 Attorneys for Defendants 10 Telephone: (702) 384-5563 || John Burton, Pro Hac Vice, California Bar No. 86029 || [email protected] THE LAW OFFICES OF JOHN BURTON || 128 North Fair Oaks Avenue Pasadena, California 91103 ||Telephone: (626) 449-8300 Attorneys for Plaintiff Stacey M. Richards ORDER 7 IT IS ORDERED that ECF No. 104 is GRANTED.

IT IS FURTHER ORDERED that the pre-Settlement Conference 19 Telephonic Conference is RESCHEDULED to 8/4/2022 at 3:00 p.m. Counsel is kindly directed to call (877) 810-9415, access code 20 2365998.

21 .

IT IS FURTHER ORDERED that the Settlement Conference is 22 RESCHEDULED to 8/5/2022 at 9:00 a.m. The Court will circulate a Zoom invitation closer to the rescheduled Settlement Conference 23 date.

DA IT IS SO ORDERED DATED: 6:57 pm, May 31, 2022 25 aon lawekaty | 26 UNITED STATES MAGISTRATE JUDGE