Green v. Minev ( 2021 )

Attorney General 2 LAURA M. GINN (Bar No. 8085) Deputy Attorney General 3 State of Nevada 100 N. Carson Street 4 Carson City, NV 89701-4717 Tel: (775) 684-1120 5 E-mail: LGinn@ag.nv.gov 6 Attorneys for Gregory Bryan, Gregory Martin, and Bob Faulkner 7 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 FREDERIC GREEN, Case No. 2:19-cv-01889-GMN-BNW 12 Plaintiff, UNOPPOSED MOTION FOR 13 v. EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT 14 DR. MICHAEL MINEV, et al., 15 Defendants. 16 Defendants Gregory Bryan, Gregory Martin, and Bob Faulkner, by and through 17 counsel, Aaron D. Ford, Attorney General for the State of Nevada, and Laura M. Ginn, 18 Deputy Attorney General, hereby move this Court for an extension of time file a Motion for 19 Summary Judgment. This Motion is made and based upon Federal Rule of Civil Procedure 20 6(b)(1)(A), the attached Points and Authorities, the papers, and pleadings on file herein, 21 and such other and further information as this Court may deem appropriate. 22 MEMORANDUM OF POINTS AND AUTHORITIES 23 Courts have inherent powers to control their dockets, see Ready Transp., Inc. v. AAR 24 Mfg, Inc., 627 F.3d 402, 404 (citations omitted), and to “achieve the orderly and expeditious 25 disposition of cases.” Chambers v. NASCO, Inc., 501 U.S. 32, 43 (1991) “Such power is 26 indispensable to the court’s ability to enforce its orders, manage its docket, and regulate 27 insubordinate [] conduct. Id. (See also Mazzeo v. Gibbons, No. 2:08–cv01387–RLH–PAL, 28 2010 WL 3910072, at *2 (D.Nev.2010)). 1 || LR IA 6-1 discusses requests for continuances. The rule states: 9 (a) A motion or stipulation to extend time must state the reasons for the extension requested and must inform the court of all 3 previous extensions of the subject deadline the court granted. (Examples: “This is the first stipulation for extension of time to 4 file motions.” “This is the third motion to extend time to take 5 discovery.”) 6 This is the first request and is requested for good cause. Former Senior Deputy 7 || Attorney General (SDAG) Brady was responsible for this case and recently left the Office 8 || of the Attorney General on September 17, 2021. As a result of former SDAG Brady leaving, 9 || this case is being reassigned to Deputy Attorney General Laura M. Ginn. 10 Counsel submits that the recent change of attorney responsible for this case 11 || constitutes good cause for granting an extension of time to thoroughly review the case and 12 file a Motion for Summary Judgment. The undersigned met and conferred with the 13 || Plaintiff via email, and he agreed to the extension. 14 Therefore, Defendants request this Court to extend the deadline from October 4, 15 2021, to November 4, 2021, to file a Motion for Summary Judgment. 16 DATED this 1st day of October, 2021. 17 AARON D. FORD 18 Attorney General By: ___/s/ Laura M. Ginn 19 Laura M. Ginn (Bar No. 8085) 20 Deputy Attorney General 91 Attorneys for Defendants 22 23 Order 24 IT IS SO ORDERED 25 DATED: 4:49 pm, October 04, 2021 26 27 Lxn~ Leas WERE 9 BRENDA WEKSLER 8 UNITED STATES MAGISTRATE JUDGE 1 CERTIFICATE OF SERVICE 2 I certify that Iam an employee of the State of Nevada, Office of the Attorney General, 3 that on October 1, 2021, I electronically filed the foregoing, UNOPPOSED MOTION 4 ||FOR EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT, via 5 || this Court’s electronic filing system. Parties who are registered with this Court’s electronic 6 || filing system will be served electronically. For those parties not registered, service was 7 || made by depositing a copy for mailing in the United States Mail, first-class postage prepaid, 8 || at Carson City, Nevada, addressed to the following: 9 Frederic Green 6718 Oak Mist Avenue 10 Las Vegas, Nevada 89139 Plaintiff, Pro Se 11 12 13 shee Office of the Nevada Attorney General 15 16 17 18 19 20 21 22 23 24 25 26 27 28