CHARLES R. GOODWIN, ESQ. 1 Nevada Bar No. 14879 2 GOODWIN LAW GROUP, PLLC 6671 S Las Vegas Blvd 3 Building D Suite 210 Las Vegas, NV 89119 4 Telephone (702) 472-9594 5 [email protected] Attorney for plaintiff Ramon Muric-Dorado 6 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 RAMON MURIC-DORADO, CASE NO. 2:18-cv-01184-JCM-EJY 10 Plaintiff, 11 v. 12 LVMPD, et. al., STIPULATION TO EXTEND DISPOSITIVE 13 MOTION DEADLINE NUNC PRO TUNC 14 Defendants. (FIFTH REQUEST) 15 16 The parties, by and through their undersigned counsel, respectfully submit this Stipulation to 17 Extend Time nunc pro tunc. Although the deadline for filing this stipulation was October 14th, 2025, 18 the parties request that the Court grant the extension as if timely filed. The brief delay in filing was 19 the result of counsel’s inadvertent miscalculation of the deadline, compounded by several urgent 20 client matters that arose on the day the stipulation was due. The mistake was promptly discovered 21 and corrected, and the parties acted in good faith throughout. No party will be prejudiced by the 22 short delay, and granting this stipulation will not disrupt the Court’s schedule or the progress of this 23 case. Good cause exists to grant this request under Federal Rule of Civil Procedure 6(b)(1)(B). 24 I. DISCOVERY COMPLETED TO DATE 25 Discovery has been completed. It officially closed on February 14, 2025. 26 II. DISCOVERY YET TO BE COMPLETED. 27 Discovery has been completed. The parties are requesting an extension of the current dispositive 28 motion and corresponding response deadlines only. 1 III. REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED. 2 The parties respectfully request a forty-five (45) day extension of the current dispositive motion 3 deadline. Counsel for Plaintiff conferred with counsel for Defendants, who agreed to the requested 4 extension. On the day the stipulation was to be finalized and filed, counsel was required to address 5 several urgent client matters that demanded immediate attention. In addition, counsel inadvertently 6 miscalendared the due date for the stipulation because there were two dates in the order, October 7 14, 2025 on page 1, and October 15, 2025 on page 3. The oversight was discovered after regular 8 business hours, at which point the stipulation could not be submitted without review by opposing 9 counsel. As a result, the stipulation is being filed one day late. 10 Federal Rule of Civil Procedure 6(b)(1)(B) authorizes the Court to extend filing deadlines where 11 the failure to act was the result of excusable neglect. Excusable neglect “is not limited to situations 12 where the failure to timely file is due to circumstances beyond the control of the filer.” Pioneer Inv. 13 Servs. Co. v. Brunswick Assocs. Ltd. P’ship,

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(1993). In 14 determining whether neglect is excusable, courts apply an equitable four-factor test considering: “(1) 15 the danger of prejudice to the opposing party; (2) the length of the delay and its potential impact on 16 the proceedings; (3) the reason for the delay; and (4) whether the movant acted in good faith.” 17 Ahanchian v. Xenon Pictures, Inc.,

, 1261 (9th Cir. 2010). This inquiry is “an equitable one” 18 that weighs all relevant circumstances. Patriot Reading Assocs., LLC v. Tadlock (In re Tadlock), No. 2:17- 19 cv-02096-JCM, at *3 (D. Nev. June 22, 2018). 20 Counsel respectfully requests a forty-five (45) day extension to respond to the dispositive motions 21 for two primary reasons. First, this case presents complex legal and factual issues in an area of law 22 with which defense counsel has limited prior experience. This is the only civil rights action in which 23 counsel has appeared, and the applicable substantive law and procedural requirements under the 24 Federal Rules of Civil Procedure are new and unfamiliar. Counsel has been diligent in reviewing the 25 relevant authorities and preparing responses but requires additional time to do so thoroughly and 26 effectively. Second, counsel’s primary practice is criminal defense litigation, which often involves 27 urgent, rapidly developing matters and court-imposed deadlines that cannot be postponed. These 28 obligations occasionally limit counsel’s ability to devote uninterrupted time to this case. Despite these 1 challenges, counsel has acted diligently and in good faith and submits that a brief extension is 2 necessary to ensure that the response is complete, accurate, and helpful to the Court. 3 All four factors support the finding of excusable neglect. The stipulation is only one day late, the 4 delay was promptly addressed once discovered, the requested extension is unopposed, and no 5 prejudice will result to any party or to the proceedings. Accordingly, good cause exists for the Court 6 to grant the extension nunc pro tunc. 7 IV. PROPOSED EXTENDED DEADLINES 8 The Parties respectfully request this court enter an order as follows: 9 Deadline Current Date Proposed New Date 10 11 Response to Dispositive Motions October 14 (or 15), 2025 November 28, 2025 12 for all Motions filed 13 Pre-Trial Order Deadline November 15, 2025 December 30, 2025 14 15 a. MOTIONS IN LIMINE/DAUBERT MOTIONS. 16 Under LR 16-3(b), any motions in limine, including Daubert motions, shall be filed and served 17 30 days prior to the commencement of Trial. Oppositions shall be filed and served and the motion 18 submitted for decision 14 days thereafter. Reply briefs will be allowed only with leave of the Court. 19 b. EXTENSIONS OR MODIFICATION OF THE DISCOVERY PLAN AND SCHEDULING 20 ORDER. 21 In accordance with LR 26-3, applications to extend any date set by the discovery plan, scheduling 22 order, or other order must, in addition to satisfying the requirements of LR 6-1, be supported by a 23 showing of good cause for the extension. All motions or stipulations to extend a deadline set forth 24 in a discovery plan shall be received by the Court not later than 21 days before the expiration of the 25 subject deadline. A request made after the expiration of the subject deadline shall not be granted 26 unless the movant demonstrates that the failure to set was the result of excusable neglect. Any 27 motion or stipulation to extend a deadline or to reopen discovery shall include: 28 (a) A statement specifying the discovery completed; 1 (b) A specific description of the discovery that remains to be completed; 2 (c) The reasons why the deadline was not satisfied or the remaining discovery was not 3 completed within the time limits set by the discovery plan; and 4 (d) A proposed scheduled for completing all discovery. \\\ 5 \\\ 6 \\\ 7 \\\ 8 \\\ 9 \\\ 10 \\\ 11 \\\ 12 \\\ \\\ 13 \\\ 14 \\\ 15 \\\ 16 \\\ 17 \\\ 18 \\\ 19 \\\ 20 \\\ 21 \\\ 22 \\\ 23 \\\ 24 25 \\\ 26 \\\ 27 \\\ 28 \\\ 1 This request for an extension is made in good faith and is joined by all parties. Although th 2 || request is not timely, the circumstances constitute excusable neglect under Fed. R. Civ. P. 6(b)(1)(B). 3 || Trial has not yet been set in this matter, and granting the requested extension will not cause any dela 4 Il in the proceedings. Because this is a joint request, no party will be prejudiced by the brief extension: Rather, the additional time will enable the parties to prepare and file dispositive motions and thei 7 respective responses in a thorough and complete manner, which will assist the Court in resolving th g || issues before it. 9 DATED this 15 day of October, 2025. DATED this 15 day of October, 2025. 10 KAEMPFER CROWELL GOODWIN LAW GROUP /s/ Travis Studdard 12 /s/ Charles R. Goodwin LYSSA S. ANDERSON 13 || CHARLES R. GOODWIN Nevada Bar No. 5781 Nevada Bar No. 14879 TRAVIS STUDDARD 14 || 3100 W Charleston Blvd Nevada Bar No. 16454 15 |} Las Vegas, NV 89102 1980 Festival Plaza Drive, Suite 650 Las Vegas, Nevada 89135 16 || Attorneys for Plaintiff 7 Ramon Muric-Dorado Attorneys tor Defendants LVMPD et. al. 18 19 20 71 IT IS SO ORDERED. 22 23 Dated October 17, 2025. 24 25 %6 Pdiid ©. “Calla 4 UNITED STATES DISTRICT JUDGE 28

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