Attorney General 2 RUDOLF M. D’SILVA (Bar No. 16227) 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) 486-3375 (phone) (702) 486-3768 (fax) 6 Email: [email protected]

7 Attorneys for Defendants The Nevada Department of Corrections 8 Jeremey Bean, Benu Clark, Ryan Griffith, Ledesma Coronel, John Henley, 9 Daniel Norrbom, Romain Smith, James Scalley, Brian Williams, 10 Kenneth Williams and Ryan Vandenbusch

11

12 UNITED STATES DISTRICT COURT

13 DISTRICT OF NEVADA

14 REYNALDO CRESPIN, Case No. 2:23-cv-01059-GMN-DJA

15 Plaintiff, ORDER RE:

16 v. DEFENDANTS’ MOTION TO EXTEND THIS COURT’S DEADLINE IN ECF 17 STATE OF NEVADA, et al., NO. 110 (FIRST REQUEST)

18 Defendants. 19 Defendants, by and through Aaron D. Ford, Attorney General for the State of 20 Nevada, and Rudolf M. D’Silva, Deputy Attorney General, respectfully request to extend 21 the deadline to comply with this Court’s Order in ECF No. 110 by seven (7) days or until 22 November 10, 2025. 23 I. BACKGROUND 24 On June 3, 2025, this Court issued an Order, ordering Parties to file a stipulation 25 either to (1) reinstate discovery and extend discovery deadlines if necessary; or (2) extend 26 the discovery deadline. ECF No. 94 at 5:15-17. On July 28, 2025, the Parties met and 27 conferred. ECF No. 99-1 at 2:3-5. Plaintiff Reynaldo Crespin (Crespin) informed defense 28 counsel that he did not want to enter into any agreements without first retaining counsel 2 himself. Id. at 2:10-15. 3 On August 4, 2025, Defendants filed a Notice Regarding This Court’s Order in ECF 4 No. 94, notifying the Court that the Parties did not come to an agreement regarding this 5 Court’s Order in ECF No. 94. See ECF No. 99. On the same day, Crespin filed a Motion to 6 extend the deadline to reinstate discovery. ECF No. 101. This Court granted Crespin’s 7 motion to extend time and ordered that by November 3, 2025, the parties either file: (1) a 8 stipulation to reinstate discovery and extend the discovery deadline if necessary; or (2) a 9 stipulation to extend the discovery stay. ECF No. 110 at 2:12-16. 10 Defense counsel scheduled a call to speak with Crespin on October 30, 2025, at 11 1:30p.m. Exhibit A – Declaration of Deputy Attorney General Rudolf D’Silva at 2:4-6. On 12 this day, while focusing on completing a motion for summary judgment in a different case, 13 defense counsel inadvertently missed the time slot to call Crespin. Id. at 2:7-9. By the time 14 defense counsel realized he did not call Crespin, the time slot to call him had passed. Id. at 15 2:10-11. Undersigned counsel immediately contacted Northern Nevada Correctional 16 Center (NNCC), where Crespin is currently housed, to see if a call could be scheduled with 17 him by noon of November 3, 2025. Id. at 2:12-13. Defense counsel was informed that soonest 18 NNCC could reschedule a call between defense counsel and Crespin was 7:30am, November 19 4, 2025. Id. at 2:14-16. As such, defense counsel has a call scheduled with Crespin to discuss 20 this Court’s Order in ECF No. 110 on November 4, 2025, at 7:30am. Id. at 2:17-18. 21 II. LEGAL STANDARD 22 When an act may or must be done within a specified time, the court may, for good 23 cause, extend the time with or without motion or notice if the court acts, or if a request is 24 made, before the original time or its extension expires. Fed R. Civ. P 6(b)(1)(A). To 25 determine whether a party's failure to meet a deadline constitutes excusable neglect, as 26 would warrant extension of time to act, the court must apply a four-factor equitable test, 27 examining: (1) the danger of prejudice to the opposing party; (2) the length of the delay and 28 its potential impact on the proceedings; (3) the reason for the delay; and (4) whether the 1 movant acted in good faith. Ahanchian v. Xenon Pictrues, Inc.,

, 1261 (9th 2 || Cir. 2010). 3 LEGAL ANALYSIS 4 Good cause exists for Defendants request to extend time the deadline to comply with 5 || this Court’s Order in ECF No. 110 to November 10, 2025. Defendants are requesting only 6 ||a weeklong extension. This short amount of time is unlikely to prejudice or delay either 7 || party in this matter. 8 Additionally, good faith for requesting this extension is present as a call was 9 ||scheduled for the parties to meet and confer on October 30, 2025. When defense counsel 10 || learned that he inadvertently missed calling Crespin at the scheduled time on this date, he 11 |;/immediately scheduled a call with Crespin at the next earliest time. The Parties are 12 scheduled to meet and confer 7:30am on November 4, 2025, only one day after this Court’s 13 || deadline in ECF No. 110. 14 CONCLUSION 15 For the reasons above, Defendants respectfully request to extend the time to comply 16 || with this Court’s Order in ECF No. 110, by seven (7) days or until November 10, 2025. 17 DATED this 3rd day of November 2025. 18 AARON D. FORD Attorney General 19 By: /s/ Rudolf M. D’Silva 20 RUDOLF M. D’SILVA (Bar No. 16227) Deputy Attorney General 21 Attorneys for Defendants 22 23 || Good cause appearing therein, IT IS SO ORDERED. 24 DATED: 11/6/2025

26 { 27 DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE 28

2 I certify that I am an employee of the State of Nevada, Office of the Attorney General, 3 and that on November 3, 2025, I electronically filed the foregoing DEFENDANTS’ 4 MOTION TO EXTEND THIS COURT’S DEADLINE IN ECF NO. 110 (FIRST 5 REQUEST) via this Court’s electronic filing system. Parties who are registered with this 6 Court’s electronic filing system will be served electronically.

7 Reynaldo Crespin (#1260528) Northern Nevada Correctional Center 8 PO Box 7000 Carson City, NV 89702 9 Pro Se

10 /s/ Jamile Vazquez Jamile Vazquez, an employee of the 11 Office of the Nevada Attorney General 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 EXHIBIT A

DECLARATION OF DAG RUDOLF M. D’SILVA

EXHIBIT A 1 A AAtRtoOrNne Dy .G FeOneRrDal 2 RUDOLF M. D’SILVA (Bar No. 16227) 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) 486-3375 (phone) (702) 486-3768 (fax) 6 Email: [email protected] 7 Attorneys for Defendants The Nevada Department of Corrections 8 Jeremey Bean, Benu Clark, Ryan Griffith, Ledesma Coronel, John Henley, 9 Daniel Norrbom, Romain Smith, James Scalley, Brian Williams, 10 Kenneth Williams and Ryan Vandenbusch 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 REYNALDO CRESPIN, Case No. 2:23-cv-01059-GMN-MDC 14 Plaintiff, 15 v. DECLARATION OF DEPUTY 16 ATTORNEY GENERAL RUDOLF M. STATE OF NEVADA, et al., D’SIVAL 17 Defendants. 18 19 20 I, Rudolf M. D’Silva, hereby declare based on personal knowledge and/or information 21 and belief, that the following assertions are true. 22 1. I am over the age of 18 and otherwise fully competent to testify to the facts 23 contained in this declaration. 24 2. I am currently employed as a Deputy Attorney General for the State of Nevada 25 and work in the Public Safety Division with the Nevada Department of Corrections 26 (NDOC). 27 3. I am currently the attorney of record for this case, case number 2:23-cv-01059- 28 1 2 John Henley, Daniel Norrbom, Romain Smith, James Scalley, Brian Williams, Kenneth 3 Williams, and Ryan Vandenbusch. 4 4. A phone call was scheduled between myself and Reynaldo Crespin (Crespin) 5 NDOC # 1260528 – an incarcerated individual housed at Northern Nevada Correctional 6 Center (NNCC) – at 1:30p.m. on October 30, 2025. 7 5. On October 30, 2025, I was working on drafting and completing a motion for 8 summary judgment in a different case which I am assigned to. While working on this 9 motion I lost track of time and forgot to call NNCC at 1:30p.m. to speak with Crespin. 10 6. By the time I realized I had missed calling Crespin it was approximately 11 4:00p.m. that same day. 12 7. Upon realizing that I had not called Crespin, I immediately contacted NNCC 13 and asked if it was possible to schedule a call with Crespin by noon on November 3, 2025. 14 I was informed that the earliest date that NNCC could reschedule Crespin’s call with me 15 was 7:30a.m. on November 4, 2025. As such, I scheduled a call with Crespin for November 16 4, 2025 at 7:30a.m. 17 8. A call is currently scheduled between myself and Crespin at 7:30a.m. on 18 November 4, 2025. 19 Furthermore, I declare under penalty of perjury pursuant to

that 20 the foregoing is true and correct. 21 EXECUTED this 3rd day of November, 2025.

22 /s/_Rudolf M. D’Silva___________ 23 Rudolf M. D’Silva

24 25 26 27 28