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 RESCHEDULE THE CONFIDENTIAL WRITTEN GREG COX, et al., EVALUATION STATEMENT FILING DEADLINE 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 Reschedule the Confidential Written Evaluation Statement Filing Deadline, current set for June 16, 2022, to a date most convenient for this Court in late July 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. This Court set a deadline to submit Confidential Written Evaluation Statements for June 16, 2022. Id. at 1:13-17.

10 Parties filed a Joint Stipulation and Order to Vacate and Reschedule the Settlement Conference on May 27, 2022. ECF No. 104. On June 1, 2022, the Court issued an Order, vacating and rescheduling the settlement conference for August 5, 2022. ECF No. 105 at 3:16-26. However, neither the Parties’ Joint Stipulation nor the Court’s Order rescheduled the deadline to submit the Confidential Written Evaluation Statement. The deadline is still set for June 16, 2022. ECF No. 103 at 1:13-17.

16 II. LEGAL DISCUSSION 17 This Court ordered that the settlement conference be rescheduled from June 24, 2022, to August 5, 2022. ECF No. 105 at 3. Parties request that the deadline to submit Confidential Written Evaluation Statement Courts be rescheduled to a date closer to the August 5, 2022, settlement conference, such as the week before August 5. 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). This request is made in good faith and is not for the purpose of causing delay.

24 / / / / / / / / / / / / / / / 1 CONCLUSION 2 Parties stipulate to this Court vacating its order in ECF No. 103 and rescheduling 3 deadline for Parties to submit Confidential Written Evaluation Statements for a date 4 convenient to this Court in late July 2022.

5 || DATED this 9th day of June 2022. DATED this 9th day of June 2022.

6 AARON D. FORD 7 Attorney General || By: __/s/ John Burton By: __/s/ William P. Shogren Richard Schonfeld, Nevada Bar No. 6815 William P. Shogren, Bar No. 14619 || [email protected] Deputy Attorney General CHESNOFF & SCHONFELD William Shogren, Bar No. 14619 10 South Fourth Street, 2"4 Floor Deputy Attorney General Las Vegas, Nevada 89101 Attorneys for Defendants ||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 15 Telephone: (626) 449-8300 Attorneys for Plaintiff Stacey M. Richards ORDER 19 IT IS ORDERED that ECF No. 106 is GRANTED to the extent 20 that the parties' confidential written evaluation statements are due by 4 p.m. on July 28, 2022.

21 DATED. 22pm, 1,202 22 eee 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 9th day of June, 2022, I caused a copy of the foregoing, JOINT ||STIPULATION AND ORDER TO RESCHEDULE THE CONFIDENTIAL WRITTEN || EVALUATION STATEMENT FILING DEADLINE, to be served, by U.S. District Court || CM/ECF Electronic Filing on the following: John Burton, Esq.

Law Offices of John Burton 128 N. Fair Oaks Ave. |) Pasadena, CA 91103 || [email protected] Richard Schonfeld, Esq.

520 S. Fourth Street, Second Floor Las Vegas, NV 89101 || [email protected] 18 Capen 19 An employee of the Office of the Attorney General