Attorney General 2 JAMIE S. HENDRICKSON (Bar No. 12770) Senior Deputy Attorney General 3 State of Nevada Office of the Attorney General 4 100 N. Carson Street Carson City, Nevada 89701-4717 5 (775) 684-1234 (phone) (775) 684-1108 (fax) 6 Email: [email protected] 7 Attorneys for Defendants Richard C. Adams and Sandra Rose-Thayer 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 KEITH BARLOW, Case No. 3:23-cv-00445-CLB 12 Plaintiff, ORDER GRANTING DEFENDANTS’ 13 v. MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR SUMMARY 14 STATE OF NEVADA, et al., JUDGMENT (Second Request) 15 Defendant. 16 Defendants, Richard C. Adams and Sandra Rose-Thayer, by and through counsel, 17 Aaron D. Ford, Nevada Attorney General, and Jamie S. Hendrickson, Senior Deputy 18 Attorney General, hereby move this Court for an extension of time to file a dispositive 19 motion. This is the second request to extend the subject deadline. 20 MEMORANDUM OF POINTS AND AUTHORITIES 21 I. FACTUAL ANALYSIS 22 This is a pro se prisoner

civil rights claim brought by offender, Keith 23 Barlow (Barlow). On October 7, 2025, this Court entered an order granting a stipulation 24 and proposed order to extend discovery deadlines in this case. ECF No. 29. Pursuant to the 25 order, the discovery deadline was extended to November 28, 2025, and the dispositive 26 motion deadline was extended to December 29, 2025.

27 Counsel for Defendants has received several new cases in November 2025 due to the 28 abrupt resignation of two Deputy Attorneys General (DAGs). Additionally, between 2 emergency motions and/or writ petitions that have required extensive time spent 3 communicating with client representatives to obtain information responses or to prepare 4 witnesses for testimony at hearings on the motions. Accordingly, Defense Counsel will be 5 unable to devote the necessary time to this matter to prepare a well-crafted dispositive 6 motion. 7 II. LEGAL STANDARD 8 A request to extend unexpired deadlines in the scheduling order must be premised 9 on a showing of good cause. Lynch v. Hernandez, Case No. 2:21-cv-01981-ART-DJA, 2024

, at *2 (D. Nev. Nov. 7, 2024) (citing Fed. R. Civ. P. 16(b)(4); Local Rule 26-3). 11 Under Local Rule 26-3, a motion to extend a date set by an order must, in addition to 12 satisfying the requirements of Local Rule IA 6-1, be supported by a showing of good cause 13 for the extension. Tankersley v. MGM Resorts International, Case No. 2:20-cv-00995-RFB- 14 DJA,

, at *4 (D. Nev. Apr. 18, 2022) (citing LR 26-3). The good cause 15 standard primarily considers the diligence of the party seeking the extension. Price v. Sims, 16 Case No. 2:21-cv-01438-CDS-DJA,

, at *2 (D. Nev. Sept. 22, 2023) (citing 17 Johnson v. Mammoth Recreations, Inc.,

(9th Cir. 1992)). The scheduling 18 order can be modified if it cannot reasonably be met despite the diligence of the party 19 seeking the extension. Castronovo-Flihan v. State Farm Mutual Automobile Insurance 20 Company, Case No. 2:20-cv-01197-JCM-DJA,

, at *1 (D. Nev. Sept. 17, 21 2021) (citing Mammoth Recreations, Inc.,

). 22 III. ARGUMENT 23 Defense Counsel respectfully requests a sixty (60) day extension of time to file 24 Defendants’ dispositive motion from the current deadline of December 29, 2025, until 25 February 27, 2026. 26 Defense Counsel was recently assigned this matter and entered his Notice of Change 27 of Deputy Attorney General on December 11, 2025, due to turnover in the Office of the 28 Attorney General (OAG), specifically the resignation of the prior handling Deputy Attorney 2 new cases to undersigned Defense Counsel. Additionally, the resignation of another DAG 3 just two weeks earlier resulted in undersigned Defense Counsel assuming responsibility 4 for several other cases, many of which required immediate attention due to the abrupt 5 nature of that particular DAG’s departure. Undersigned Defense Counsel was further 6 preoccupied with several depositions in early December that were scheduled several weeks 7 ago and required substantial preparation time. These circumstances, coupled with multiple 8 orders to respond to emergency motions in November and December 2025 and multiple 9 impending deadlines in existing cases, resulted in Defense Counsel requiring additional 10 time to prepare a dispositive motion in this matter. 11 Undersigned Defense Counsel must interview the named defendants, review the 12 pleadings and discovery completed thus far, and obtain affidavits in support of a dispositive 13 motion. The necessary communications to acquire the information and documents to 14 prepare a dispositive motion are also complicated by the holiday season because client 15 representatives are more likely to take vacations or travel for the holidays. Accordingly, 16 Defendants request an extension of sixty (60) days to the existing deadline to file dispositive 17 motions as follows: 18 A. Current Deadlines 19 Dispositive motion deadline: December 29, 2025 20 Joint pretrial order (if no dispositive motions filed): January 28, 2026 21 B. Proposed Deadlines 22 Dispositive motion deadline: February 27, 2026 23 Joint pretrial order (if no dispositive motions filed): March 30, 20261 24 C. Good Cause Supports this Request 25 Federal Rule of Civil Procedure 16(b) allows parties to request extensions of 26 deadlines set in the Court’s scheduling order. Good cause exists for the extension. LR 26-3. 27 1 Thirty (30) days from February 27, 2026, is Sunday, March 29, 2026. Therefore, 28 the deadline to file the Joint Pretrial Order is moved to the next judicial day. 1 || Counsel for Defendants needs additional time due to turnover at the OAG, which resulted 2 the assignment of several new cases that required immediate attention, as well as 3 |} multiple orders to respond to emergency motions in other matters. 4 Defendants assert that the requisite good cause is present to warrant the requested 5 ||/extension of time. Moreover, Plaintiff will suffer no prejudice due to an extension of the 6 || dispositive motion deadline. Finally, this is the second request to extend the subject 7 || deadline. 8 ||IV. CONCLUSION 9 Defendants respectfully request this Court extend the deadline for dispositive 10 || motion in this matter. Defendants assert the requisite good cause is present to warrant an 11 ||extension of time. Therefore, Defendants request additional time, up until February 27, 12 || 2026, to file dispositive motions in this matter. 18 DATED this 12th day of December 2025. 14 AARON D. FORD Attorney General 15 16 By: /s/ Jamie S. Hendrickson JAMIE 8S. HENDRICKSON, Bar No. 12770 17 Senior Deputy Attorney General 18 Attorneys for Defendants 19 || IT IS SO ORDERED. 20 DATED: December 15, 2025 21 □□ 22 23 UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 2 The first extension of the dispositive motion deadline occurred via a stipulation and order entered on October 7, 2025. ECF No. 29.