1 Ashlee B. Hesman, No. 012740 STRUCK LOVE ACEDO, PLC 2 3100 West Ray Road, Suite 300 Chandler, Arizona 85226 3 Tel.: (480) 420-1600 Fax: (480) 420-1695 4 [email protected]

5 James E. Harper Nevada Bar No. 9822 6 HARPER | SELIM 1935 Village Center Circle 7 Las Vegas, Nevada 89134 Phone: (702) 948-9240 8 Fax: (702) 778-6600 Email: [email protected] 9 Attorneys for Defendants CoreCivic, 10 Gutierrez, and Jimenez 11 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 Christopher Busby, Case No. 2:25-cv-01823-JAD-DJA

15 Plaintiff, DEFENDANTS’ MOTION TO 16 v. EXTEND DEADLINE TO RESPOND TO PLAINTIFF’S 17 CORECIVIC, INC., a foreign corporation; COMPLAINT Officer Gutierrez, individually and in his 18 official capacity; Officer Jimenez, individually (Renewed First Request) and in her official capacity; DOES 1 through 19 10 inclusive; and ROE Corporations 1 through 10, inclusive; 20 Defendants. 21 22 Defendants CoreCivic, Inc., Officer Gutierrez, and Officer Jimenez (collectively, 23 “Defendants”), pursuant to the Court’s October 6, 2025 Order (Dkt. 6), file a renewed motion 24 for a 14-day extension of time to respond to Plaintiff’s Complaint. 25 On June 25, 2025, Plaintiff filed a Complaint against Defendants in the Fifth Judicial 26 District Court, Nye County, Nevada, captioned Christopher Busby v. CoreCivic, Inc., et al., 27 Case No. CV25-0356. (Dkt. 1-3.) Defendants removed this action to this Court on September 28 1 26, 2025. (Dkt. 1.) Pursuant to Fed. R. Civ. P. 81(c)(2)(C), a defendant who did not answer 2 before removal must file a responsive pleading within seven days after the notice of removal 3 is filed. Accordingly, Defendants’ responsive pleading was due October 3, 2025. On October 4 2, 2025, the Parties, pursuant to LR IA 6-1, timely filed a Joint Stipulated Motion to Extend 5 Defendants’ Deadline to Respond to Plaintiff’s Complaint (“Joint Stipulated Motion”) 6 requesting that the Court extend Defendants’ responsive pleading deadline by 30 days to 7 November 3, 2025. (Dkt. 5.) On October 6, 2025, the Parties’ Joint Stipulated Motion was 8 denied, without prejudice, for failure to provide good cause pursuant to LR IA 6-1. (Dkt. 6.) 9 Defendants provide good cause below. 10 Defendants’ requested extension1 is due to Defense counsel’s conflicting deadlines 11 and travel schedule. Specifically, Defense counsel was out of the office from September 30 12 through October 5, 2025, due to an illness and pre-booked travel. Additionally, Defense 13 Counsel has several pretrial deadlines in various matters including, but not limited to: a 14 Motion for Summary Judgment due October 6, 2025 in Packard v. Ashworth, et al., No. 2:23- 15 cv-00793-SRB-CDB (D. Ariz.); expert disclosures due October 13, 2025, in Daniele v. 16 Sheridan, et al., No. 2:24-cv-01909-SHD-ASB (D. Ariz.); and a trial setting conference and 17 argument on October 14, 2025 in Williams v. Yuma County, et al., No. 2:22-cv-00154-MTL- 18 CDB (D. Ariz.). 19 Granting Defendants this brief extension will not prejudice Plaintiff as he previously 20 agreed to a longer, 30-day extension. (Dkt. 5.) Defendants acted in good faith with respect 21 to the Joint Stipulated Motion. This instant request to extend the deadline for Defendants to 22

1 Given that the Parties’ Joint Stipulated Motion was timely filed on October 2, 2025, 23 there was no excusable neglect in the filing of the request for the extension before Defendants’ October 3, 2025 responsive pleading deadline. However, to the extent the Court requires a 24 showing of excusable neglect pursuant to LR IA 6-1, the failure to include counsel’s various conflicts and travel as a showing of good cause was attributable to negligence, thus giving 25 rise to excusable neglect. See R.J. Armstrong Living Tr. v. Holmes,

, at *2 (D. Nev. Jan. 31, 2024) (“Excusable neglect is an ‘elastic concept’ that is not limited strictly 26 to omissions caused by circumstances beyond the control of the movant…” [and] “may encompass situations in which a failure to comply with a filing deadline is attributable to 27 negligence.” (citation omitted)). Undersigned counsel apologizes to the Court for the oversight and has amended the requested extension by two weeks. 28 1 | respond to Plaintiff's Complaint is also made in good faith and not for delay purposes. No 2 || deadlines have been set and the parties have agreed to extend the deadline. Accordingly, 3 || Defendants respectfully request that the Court grant the instant Motion and extend 4 | Defendants’ deadline to respond to Plaintiff's Complaint from October 3 to October 17, 2025. 5 Conclusion 6 For these reasons, Defendants request that their Motion be granted. 7 DATED this 6th day of October 2025. 8 STRUCK LOVE ACEDO, PLC 9 By /s/ Ashlee B. Hesman 10 Ashlee B. Hesman 3100 West Ray Road, Suite 300 1 Chandler, Arizona 85226 D [email protected] James E. Harper 13 HARPER | SELIM 1935 Village Center Circle 14 Las Vegas, NV 89134 15 Attorneys for Defendants CoreCivic, Gutierrez, and Jimenez 16 17 18 19 IT IS SQ ORDERED:

21 UNITED STATES;MAGISTRATE JUDGE 22 23 DATED: 10/7/2025 24 25 26 27 28

1 CERTIFICATE OF SERVICE 2 I hereby certify that on October 6, 2025, I electronically transmitted the attached 3 document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice 4 of Electronic Filing to the following CM/ECF registrants:

5 Marjorie Hauf Matthew G. Pfau 6 Arun Luckoor [email protected] 7 Attorneys for Plaintiff 8 /s/ E. Percevecz 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28