1 RTaHnEo jGoyU GHuAha L (ASBWN F 3I1R5M96 8) 2 [email protected] 1100 Town and Country Road, 3 Suite 1250 Orange, CA 92868 4 (310) 564-6041 5 Jonathan A. Weinman (SBN 256553) LAW OFFICES OF JONATHAN A. WEINMAN, APC 6 [email protected] 3780 Kilroy Airport Way, Suite 200 7 Long Beach, CA 90806 (213) 200-2596 8 Attorneys for Plaintiffs, 9 SHANNEL HEAD and GEORGE HEAD 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 SHANNEL HEAD, an individual; and Case No: 3:24-cv-00036-MMD-CLB GEORGE HEAD, an individual 14 ORDER GRANTING 15 Plaintiffs, STIPULATION TO EXTEND v. TIME TO FILE PLAINTIFF’S 16 OPPOSITION TO AND WHITE PINE COUNTY, a political DEFENDANT’S REPLY IN 17 subdivision of the State of Nevada; and SUPPORT OF DEFENDANT’S 18 DOES 1-25, MOTION FOR SUMMARY JUDGMENT 19 Defendant(s). (Plaintiff’s First Request) 20 21 Plaintiffs SHANNEL HEAD and GEORGE HEAD (together, “Plaintiffs”) and 22 Defendant WHITE PINE COUNTY (“Defendant”) (collectively, the “Parties”) through 23 their counsel of record, pursuant to Local Rules LR IA 6-1 and LR 26-3, hereby stipulate 24 to request a two-week extension of the September 29, 2025 deadline for Plaintiffs to file 25 their Opposition to Defendant’s Motion for Summary Judgment, and a commensurate two- 26 week extension for Defendant to file its Reply papers in support thereof. Plaintiff’s first 27 request for an extension of the Parties’ respective deadlines to file these papers is requested 28 in good faith and not for the purpose of delay. 1 On August 13, 2025, Defendant filed a Motion to Extend Time to File Motion for 2 Summary Judgment. ECF No. 56. On August 14, 2025, the Court granted Defendant’s 3 Motion to Extend Time to File Motion for Summary Judgment, setting a due date for 4 September 8, 2025. See ECF No. 58. On September 8, 2025, Defendant filed its Motion 5 for Summary Judgment. See ECF No. 60. 6 The current due date for Plaintiff’s Opposition is September 29, 2025. 7 MEMORANDUM OF POINTS AND AUTHORITIES 8 I. LEGAL AUTHORITIY 9 Fed. R. Civ. P. 16(b)(4) governs the modification of scheduling orders. Rule 16 10 provides that “[a] schedule may be modified only for good cause and with the judge’s 11 consent.” Fed. R. Civ. P. 16(b)(4). The “good cause” standard focuses primarily on the 12 movant’s diligence. Coleman v Quaker Oats Co.,

, 1294-95 (9th Cir. 2000). 13 Local Rule IA 6-1(a) requires that a “stipulation to extend time must state the 14 reasons for the extension requested and must inform the court of all previous extensions of 15 the subject deadline the court granted.” Local Rule 26-3 further provides that a “motion or 16 stipulation to extend any date set by [any] scheduling order[] or other order must, in 17 addition to satisfying the requirements of LR IA 6-1, be supported by a showing of good 18 cause for the extension.” As detailed herein, the Parties stipulation meets these standards. 19 REASON FOR EXTENSION: Specifically, counsel for Plaintiff is currently dealing 20 with urgent personal and family health care matters that are interfering with counsel’s 21 ability to meet the current September 29, 2025, deadline for Plaintiffs to file their 22 Opposition to Defendant’s Motion for Summary Judgment. In addition, counsel for 23 Defendant will be on a prepaid nonrefundable family event from September 24 until 24 October 13, 2025. As a result, under the current briefing schedule, Defendant’s Reply brief 25 would be due on October 13, 2025, the day she returns to her office. Accordingly, the 26 parties request an additional extension of 14 days to file their remaining papers related to 27 Defendant’s Motion for Summary Judgment. 28 D. PROPOSED REVISED BRIEFING SCHEDULE: ] 1. Summary of Proposed Changes: 2 || (Tarrant Denatines [Proposed Denatines +d 5 DATED September 22, 2025 6 THE GUHA LAW FIRM LAW OFFICES OF JONATHAN A. WEINMAN, AP 7 WOOLDRIDGE LAW LTD. 8 By: _/s/Ranojoy Guha 9 Ranojoy Guha, Esq. (pro hac) Jonathan A. Weinman, Esq. (pro hac) 10 Nicolas Woolridge, Esq. 1 Attorneys for Plaintiffs 12 LEMONS, GRUNDY & EISENBERG 13 By: /s/Rebecca Bruch 14 REBECCA BRUCH, ESQ. (SBN7289) 15 6005 Plumas St., Third Floor Reno, Nevada 89519 16 Attorneys for Defendant 17 18 19 20 21 IT IS SO ORDERED: 22 23 DATED: September 23, 2025 24 25 UNITED STATES DISTRICT JUDGE 26 27 28 GRUNDY SENBERG STREET