Michael Leon Williams v. State of Nevada, et al.

Attorney General SAMUEL L. PEZONE JR. (Bar No. 15978) Deputy Attorney General State of Nevada Office of the Attorney General 1 State of Nevada Way, Suite 100 Las Vegas, Nevada 89119 (702) 486-4070 (phone) (702) 486-3768 (fax) Email: [email protected] Attorneys for Defendants John Keast and Melissa Mitchell 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA MICHAEL LEON WILLIAMS, Case No. 3:22-cv-00430-CLB 12 Plaintiff, ORDER GRANTING STIPULATION v. TO EXTEND THE TIME TO FILE DEFENDANTS’ REPLY IN STATE OF NEVADA, et al., SUPPORT OF ECF NO. 75 15 Defendants. (FIRST REQUEST) 16 Plaintiff, Michael Leon Williams, by and through counsel, Andre M. Lagomarsino, and Taylor M. Jorgensen, of Lagomarsino Law, and Defendants, John Keast and Melissa Mitchell, by and through counsel, Aaron D. Ford, Nevada Attorney General, and Samuel L. Pezone Jr., Deputy Attorney General, of the State of Nevada, Office of the Attorney General, hereby stipulate and agree to extend the time to file Defendants’ Reply in Support of their Motion for Summary Judgement (ECF No. 75). This is the parties’ first request for an extension of this deadline. There is good cause for this Court to grant an extension.

23 MEMORANDUM OF POINTS AND AUTHORITIES I. LEGAL STANDARD 25 Pursuant to Fed. R. Civ. P. 6(b), the “court may, for good cause, extend the time . . .

26 with or without motion or notice . . . if a request is made, before the original time or its extension expires,” or “on motion made after the time has expired if the party failed to act because of excusable neglect.”

2 the exercise of due diligence, [the party was] unable to meet the” subject deadline. Cruz v. City of Anaheim, CV-1003997-MMM-JEMX, 2011 WL 13214312, at *2 (C.D. Cal. Dec. 19, 2011) (citing Zivkovic v. Southern California Edison Co., 302 F.3d 1080, 1087 (9th Cir. 2002); Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)). Prejudice to the opposing party is a factor in determining good cause, though lack of prejudice is “not a prerequisite.” Id. II. ARGUMENT 9 The parties request an extension of the deadline to reply in support of Defendants’ Motion for Summary Judgment (ECF No. 75). Pursuant to LR 7-2(b), the deadline to file this reply is November 18, 2025. Based upon the foregoing, there is good cause to extend this deadline by seven (7) days, or until November 25, 2025.

13 Counsel for Defendants sustained a large second degree burn to his left thigh while attempting to steep a pot of tea in his office on November 5, 2025. Counsel was triaged at the University Medical Center (UMC) that day, and counsel has since attended several outpatient appointments with UMC’s Burn and Wound Clinic. Due to these appointments and the need to perform daily dressing changes, Defendants’ counsel has been intermittently out of office since November 6, 2025, which has prevented counsel from making any substantial progress in drafting Defendants’ reply brief in support of their Motion for Summary Judgment.

21 A one-week extension should allow Defendants’ counsel adequate time to finalize Defendants’ reply brief. The parties maintain that they will not be prejudiced by this short extension. Accordingly, the parties respectfully request that this extension be granted for good cause shown. See Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1260 (9th Cir. 2010) (holding that the “district court abused its discretion in denying party’s timely motion” to extend time because the party “demonstrated the ‘good cause’ required by Rule 6, and because there was no reason to believe that [the party] was acting in bad faith or was misrepresenting his reasons for asking for the extension”).

1 CONCLUSION 2 Based on the foregoing, there is good cause to extend the reply brief deadline. The || parties respectfully request that this Court extend the deadline to file Defendants’ Reply 4 Support of ECF No. 75 until November 25, 2025.

5 |} DATED this 17th day of November, 2025. DATED this 17th day of November, 2025.

6 || AARON D. FORD Attorney General /s/ Samuel L. Pezone, Jr. /s/ Taylor N. Jorgensen ||Samuel L. Pezone, Jr. (Bar No. 15978) Andre M. Lagomarsino (Bar No. 6711) Deputy Attorney General Taylor N. Jorgensen (Bar No. 16259) 9 3005 W. Horizon Ridge Pkwy., No. 241 Attorneys for Defendants Henderson, Nevada 89052 10 (702) 383-2864 (phone) u Attorneys for Plaintiff 12 ORDER 13 IT IS SO ORDERED. .

A Dated: November 17, 2025.

15 UNITED STATES\MAGISTRATE JUDGE