Doe v. Lombardo

Nevada Bar No. 8478 [email protected] GUINASSO LAW, LTD. 5371 Kietzke Lane Reno, NV 89511 Benjamin W. Bull* Peter A. Gentala* Dani Bianculli Pinter* Christen M. Price* Victoria Hirsch* NATIONAL CENTER ON SEXUAL EXPLOITATION 1201 F Street, NW, Suite 200 Washington, DC 20004 202.393.7245 [email protected] *Pro Hac Vice Applications Forthcoming UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA JANE DOE, CASE NO.: 3:24-cv-00065-MMD-CLB Plaintiffs, 16 ORDER GRANTING STIPULATION v. FOR EXTENSION OF TIME FOR 17 PLAINTIFF TO FILE AN OPPOSITION JOSEPH LOMBARDO, Governor of Nevada TO STATE DEFENDANTS’ MOTION TO in his official capacity; AARON FORD, DISMISS [ECF NO. 24], FOR Attorney General of Nevada in his official STATE DEFENDANTS TO FILE A capacity; NYE COUNTY; ELKO COUNTY; REPLY TO PLAINTIFF’S OPPOSITION TO [ECF NO. 24], FOR PLAINTIFF STOREY COUNTY; WESTERN BEST, INC, 20 TO FILE AN OPPOSITION TO STATE D/B/A CHICKEN RANCH; WESTERN BEST, DEFENDANTS’ MOTION TO STAY LLC; DESERT ROSE CLUB, LLC; [ECF NO. 30], AND FOR STATE HACIENDA ROOMING HOUSE, INC. D/B/A DEFENDANTS TO FILE A REPLY TO BELLA’S HACIENDA RANCH; MUSTANG PLAINTIFF’S OPPOSITIONS TO [ECF RANCH PRODUCTIONS, LLC D/B/A NO. 24 & 30] MUSTANG RANCH LOUNGE, LLC; AND LEONARD “LANCE” GILMAN in his official [FIRST REQUEST] capacity, 25 Defendants.

2 Joseph Lombardo and Aaron Ford (“State Defendants”) by and through their counsel of record, and hereby stipulate and agree to the following regarding State Defendants’ Motion to Dismiss [ECF No. 24] filed on April 1, 2024, and State Defendants’ Motion to Stay Case or Discovery [ECF No. 30] filed on April 2, 2024: 7 1. This is Plaintiff’s first request for extension of time to file an opposition to State 8 Defendants’ Motion to Dismiss [ECF No. 24].

9 2. This is State Defendants first request for extension of time to file a reply to Plaintiff’s opposition to State Defendants’ Motion to Dismiss [ECF No. 24], once filed.

3. This is also Plaintiff’s first request for extension of time to file an opposition to State Defendants’ Motion to Stay Case or Discovery [ECF No. 30] on April 2, 2024.

4. State Defendants first request for extension of time to file a reply to Plaintiff’s 15 opposition to State Defendants’ Motion to Stay Case or Discovery [ECF No. 30], once 16 filed.

5. Plaintiff shall have an extension of 21-days to file and serve her Opposition to State Defendants’ Motion to Dismiss [ECF No. 24], making the new deadline May 6, 2024.

6. State Defendants shall have 21-days to file and serve their reply to Plaintiff’s opposition to State Defendants’ Motion to Dismiss [ECF No. 24], once filed.

22 7. Plaintiff shall also have an extension of 21-days to file and serve her Opposition to 23 State Defendants’ Motion to Stay Case or Discovery [ECF No. 30], making the new 24 deadline May 7, 2024.

8. State Defendants shall have 21-days to file and serve their reply to Plaintiff’s opposition to State Defendants’ Motion to Stay Case or Discovery [ECF No. 30], once filed.

2 Good cause for the extension exists and is pursuant to Local Rules, Plaintiff Jane Doe 3 has “14 days after service of the motion” to file and serve her reply. See LR 7-2(b).

4 Fourteen days after filing the Motion to Dismiss [ECF No. 24] is Monday, April 15, 5 2024, and Tuesday, April 16, 2024, for the Motion to Stay Case or Discovery [ECF 6 No. 30]. More specifically, Counsel for Plaintiff have three deadlines in the instant case 7 within two days: Opposition to State Defendants’ Motion to Dismiss on April 15, 2024; 8 Joint Case Management Report on April 15, 2024; and Opposition to State Defendants’ 9 Motion to Stay Case or Discovery on April 16, 2024. In addition, Counsel is filing a 10 petition for writ of certiorari in the case Williams v. Sisolak, 2:21-CV-01676 that is due 11 on April 17, 2024. Finally, counsel for Plaintiff, Mr. Guinasso, has also switched law 12 firms since the Motion to Dismiss [ECF No. 24] and Motion to Stay Case or Discovery 13 [ECF No. 30] were filed, and is currently undergoing orientation at his new firm. To 14 provide the parties sufficient time to prepare responsive pleadings, , the parties 15 amicably agreed upon the above extension.

16 10.It is within the discretion of the Court to grant an extension of time. See, e.g., 17 Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1258 (9th Cir. 2010). The instant 18 Stipulation is not filed for the purpose of delay. Due to the converging reply deadlines in the instant case, deadline for petition for writ of certiorari in Williams v. Sisolak, and Plaintiff’s counsel changing law firms, the parties will have insufficient time to prepare adequately well-briefed responsive pleadings to these motions.

22 /// /// /// /// /// /// /// DATED this 12th day of April, 2024. DATED this 12th day of April, 2024.

AARON FORD GUINASSO LAW, LTD. Attorney General /s/ Iva K. Todorova /s/ Jason D. Guinasso __________________________ Jason D. Guinasso, Esq.

Marni K. Watkins (Bar No. 9674) Nevada Bar No. 8478 Chief Litigation Counsel 5371 Kietzke Lane Sabrena K. Clinton (Bar No. 6499) Reno, Nevada 89511 Deputy Attorney General [email protected] Iva K. Todorova (Bar No. 15827) Attorney for Plaintiffs Senior Deputy Attorney General Office of the Attorney General E. Washington Ave., Ste. 3900 Las Vegas, Nevada 89101 [email protected] [email protected] [email protected] Attorneys for Governor Joseph Lombardo and Attorney General Aaron Ford 1 ORDER 2 11. HEREBY ORDERED that Plaintiff shall have an extension of 21-days to file 3 and serve her Opposition to State Defendants’ Motion to Dismiss [ECF No. 24], 4 making the new deadline May 6, 2024.

12. State Defendants shall have 21-days to file and serve their reply to Plaintiff's 4 opposition to State Defendants’ Motion to Dismiss [ECF No. 24], once filed.

8 13. Plaintiff shall also have an extension of 21-days to file and serve her Opposition to 9 State Defendants’ Motion to Stay Case or Discovery [ECF No. 30], making the new 10 deadline May 7, 2024.

14. State Defendants shall have 21-days to file and serve their reply to Plaintiff's opposition to State Defendants’ Motion to Stay Case or Discovery [ECF No. 30], once filed.

16 IT IS SO ORDERED THIS 12" Day of April 2024.

18 DISTRICT COURT JUDGE || Respectfully Submitted by: GUINASSO LAW, LTD. By: /s/ Jason D. Guinasso Jason D. Guinasso Nevada Bar No. 8478 GUINASSO LAW, LTD. 5371 Kietzke Lane Reno, NV 89511 Attorney Plaintiffs Page 5 of 5