1 A AAtRtoOrNne Dy .G FeOneRrDal 2 SAMUEL L. PEZONE, JR. (Bar No. 15978) Deputy Attorney General 3 State of Nevada Office of the Attorney General 4 1 State of Nevada Way, Suite 100 Las Vegas, Nevada 89119 5 (702) 486-4070 (phone) (702) 486-3768 (fax) 6 Email: [email protected]

7 Attorneys for Defendants

8 UNITED STATES DISTRICT COURT

9 DISTRICT OF NEVADA

10 RAMSEY RHONDA, Case No. 2:24-cv-02364-CDS-MDC

11 Plaintiff, DEFENDANTS’ MOTION FOR EXTENSION OF TIME TO 12 v. RESPOND TO THE COMPLAINT

13 NAJERA, et al., [FIRST REQUEST]

14 Defendants. 15 Defendants, Gabriela Najera, Jennifer Nash, and Maria Raines, and William 16 Reubart, hereby request an extension of time to file his responsive pleading to the 17 Complaint, ECF No. 7. This is Defendant’s first requested extension of the subject deadline. 18 MEMORANDUM OF POINTS AND AUTHORITY 19 I. APPLICABLE LAW 20 Pursuant to Fed. R. Civ. P. 6(b), the “court may, for good cause, extend the time . . . 21 with or without motion or notice . . . if a request is made, before the original time or its 22 extension expires,” or “on motion made after the time has expired if the party failed to act 23 because of excusable neglect.” 24 To demonstrate good cause, the party seeking modification must show “that, even in 25 the exercise of due diligence, [the party was] unable to meet the timetable set forth in the 26 order.” Cruz v. City of Anaheim, CV-1003997-MMM-JEMX,

, at *2 (C.D. 27 Cal. Dec. 19, 2011) (citing Zivkovic v. Southern California Edison Co.,

, 1087 28 (9th Cir. 2002); Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992)). 1 Prejudice to the opposing party is a factor in determining good cause, though lack of 2 prejudice is “not a prerequisite.”

3 II. ARGUMENT 4 Defendants seek an extension of time to file their responsive pleading to the 5 operative Complaint, ECF No. 7. Pursuant to ECF No. 12, the deadline to file a response 6 to the Complaint is September 29, 2025. Good cause is present to extend this deadline until 7 October 29, 2025. 8 On August 24, 2025, the State of Nevada’s computer systems suffered a large-scale 9 cyberattack. This attack resulted in all computer systems being taken offline, including 10 the Office of the Attorney General’s case management systems. These systems were not 11 fully restored until September 26, 2025, which prevented counsel from drafting and timely 12 filing a responsive pleading to the operative Complaint. In addition, undersigned counsel 13 has several upcoming deadlines, many of them previously extended due to the outage, 14 which will prevent counsel from drafting and filing a responsive pleading within the next 15 few weeks. A lengthier extension is requested to obviate the need for several smaller 16 extensions. 17 A thirty (30) day extension to October 29, 2025, will allow undersigned counsel 18 adequate time to finalize Defendants’ responsive pleading. Plaintiff will likely not be 19 prejudiced by this extension. 20 Accordingly, Defendants respectfully request that this extension be granted for good 21 cause shown. See Ahanchian v. Xenon Pictures, Inc.,

, 1260 (9th Cir. 2010) 22 (holding that the “district court abused its discretion in denying party’s timely motion” to 23 extend time because the party “demonstrated the ‘good cause’ required by Rule 6, and 24 because there was no reason to believe that [the party] was acting in bad faith or was 25 misrepresenting his reasons for asking for the extension”). 26 III. CONCLUSION 27 Good cause exists for an extension of the deadline to respond to the Complaint. This 28 is the first request presented by Defendants seeking an extension of the deadline. There 1 will be no prejudice to the Plaintiff in granting a thirty-day extension of time until October 2 29, 2025. 3 DATED this 29th day of September, 2025.

4 AARON D. FORD Attorney General 5 By: /s/ Samuel L. Pezone Jr. 6 SAMUEL L. PEZONE JR. (Bar No. 15978) Deputy Attorney General 7 Attorneys for Defendants 8

9 IT IS SO ORDERED. Under LR 7-2(d), the failure of an opposing party to file points and authorities in response to any motion, except a motion under 10 Fed. R. Civ. P. 56 or a motion for attorney’s fees, constitutes a consent to the granting of the motion. No one filed an opposition and the time to 11 do so has passed. The opposing party has thus consented. 12 13 14 15 ___________________________ Hon. Maximiliano D. Couvillier III 16 United States Magistrate Judge Dated: 10-16-25 17 18 19 20 21 22 23 24 25 26 27 28 1 CERTIFICATE OF SERVICE 2 I certify that I am an employee of the State of Nevada, Office of the Attorney General, 3 and that on September 29th, 2025, I electronically filed the foregoing DEFENDANTS’ 4 MOTION FOR EXTENSION OF TIME TO RESPOND TO THE COMPLAINT 5 [FIRST REQUEST] via this Court’s electronic filing system. Parties who are registered 6 with this Court’s electronic filing system will be served electronically. For those parties not 7 registered, service was made by mailing a copy at Las Vegas, Nevada, addressed to the 8 following:

9 Rhonda Ramsey #1275100 559 S. Taylor 10 Decatur, IL 62522 Plaintiff, Pro Se 11

12 /s/ Andrea Beckett ANDREA BECKETT, an employee of the 13 Office of the Nevada Attorney General

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