Rios v. Bryan

1 LYSSA S. ANDERSON Nevada Bar No. 5781 KRISTOPHER J. KALKOWSKI Nevada Bar No. 14892 KAEMPFER CROWELL 1980 Festival Plaza Drive, Suite 650 Las Vegas, Nevada 89135 Telephone: (702) 792-7000 Fax: (702) 796-7181 [email protected] [email protected] Attorneys for Defendant, Joseph Lombardo UNITED STATES DISTRICT COURT DISTRICT OF NEVADA JUAN C. RIOS, CASE NO.: 2:17-cv-03074-RFB-BNW 12 Plaintiff, vs. STIPULATION TO EXTEND TIME TO 13 FILE A REPLY IN SUPPORT OF THE JOSEPH LOMBARDO, CLARK COUNTY MOTION FOR RECONSIDERATION SHERIFF; and DOES 1-100, ROE [ECF No. 79] Corporations I – X, inclusive, Defendants.

17 Defendant Joseph Lombardo (“Lombardo”), through his counsel, Kaempfer Crowell, and Plaintiff Juan C. Rios, through his counsel, Hamilton Law, stipulate and agree to extend the current deadline of November 7, 2023, for Lombardo to file a Reply in support of the Motion for Reconsideration, (ECF No. 79), by seven days, which will create a new deadline of November 14, 2023.

22 1. On October 17, 2023, Defendant Lombardo filed a Motion for Reconsideration, (ECF No. 79).

24 2. Plaintiff timely filed a Response, (ECF No. 80), on October 31, 2023.

1 3. Federal Rule of Civil Procedure 6(b) and Local Rule IA 6-1 impose a good cause standard to extend the deadline file a Reply. “‘Good cause’ is a non-rigorous standard that has been construed broadly across procedural and statutory contexts.” Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1259 (9th Cir. 2010).

5 4. Good cause exists to extend the deadline for Lombardo to file the Reply by one week in light of Lombardo’s counsel briefly being ill and deadlines in other matters before the Court arising at the same time as the Reply’s current due date of November 7, 2023.

8 5. An extension of time will ensure that the Court has appropriate briefing on Lombardo’s Motion for Reconsideration before making a ruling. Neither party will suffer prejudice from an extension of time.

11 DATED this 6th day of November, 2023.

12 KAEMPFER CROWELL HAMILTON LAW By: /s/ Lyssa S. Anderson By: /s/ Ryan A. Hamilton LYSSA S. ANDERSON RYAN A. HAMILTON, ESQ.

14 Nevada Bar No. 5781 Hamilton Law KRISTOPHER J. KALKOWSKI 5125 S. Durango Drive 15 Nevada Bar No. 14892 Las Vegas, NV 89113 1980 Festival Plaza Drive, Suite 650 Attorneys for Plaintiff 16 Las Vegas, Nevada 89135 Attorneys for Defendant 17 Joseph Lombardo IT IS SO ORDERED.

DATED this 7th day of November 2023.

22 UNITED STATES DISTRICT COURT JUDGE