Dittmar v. City of North Las Vegas

• Court: District Court, D. Nevada
• Decided: March 12, 2024
• Docket: 2:17-cv-02916
• Status: Unknown

Opinion

1 MELANIE A. HILL, ESQ. Nevada Bar No. 8796 2 MELANIE HILL LAW PLLC 1925 Village Center Circle, Suite 150 3 Las Vegas, NV 89134 Tel: (702) 362-8500 4 Fax: (702) 362-8505 Email: Melanie@MelanieHillLaw.com 5 Attorney for Plaintiff Pamela Dittmar 6 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 ***** 11 12 PAMELA DITTMAR, Case No. 2:17-cv-02916-JAD-BNW 13 Plaintiff, STIPULATION AND ORDER TO EXTEND DEADLINES FOR PLAINTIFF 14 v. TO FILE HER OBJECTION TO DEFENDANT’S BILL OF COSTS [ECF 15 CITY OF NORTH LAS VEGAS, a municipal NO. 203], AND RESPONSE TO MOTION corporation, 16 FOR ATTORNEYS’ FEES [ECF NO. 204] Defendant. 17 (First Request) ECF No. 205 18 19 NOW COMES the Plaintiff, Pamela Dittmar, by and through her attorneys, Melanie Hill and 20 Melanie Hill Law PLLC, and Defendant, City of North Las Vegas, by and through its attorneys, R. 21 Todd Creer, Kaitlin H. Paxton, and Kamer Zucker Abbott, who hereby stipulate that the deadlines 22 for Plaintiff to file her objection to Defendant’s Bill of Costs [ECF No. 203] and response to 23 Defendant’s Motion for Attorneys’ Fees [ECF No. 204] be extended from their current deadline of 24 March 12, 2024 to April 2, 2024, and April 5, 2024 respectively. This stipulation is filed pursuant to 25 Local Rule IA 6-1. 26 / / / 27 / / 28 1 This is the first request for an extension of both of these deadlines which all fall on the same 2 day, March 12, 2024. In support of this stipulation for extension of these deadlines, the parties state

3 as follows: 4 1. The current deadline for Plaintiff to file her objection to Defendant’s Bill of Costs 5 [ECF No. 203] and response to Defendant’s Motion for Attorneys’ Fees [ECF No. 204] is March 12, 6 2024. 7 2. Counsel for Plaintiff will be out of town and on a cruise for her daughter’s Spring 8 Break vacation from March 8-17, 2024. Due to the Wi-Fi issues Plaintiff’s counsel experienced last 9 time on a cruise, counsel requested a stipulated extension of the deadline, while counsel is out of the 10 country for her daughter’s Spring Break vacation. For this reason, as well as the good cause 11 articulated below, Plaintiff’s counsel requested a stipulated extension of the deadline to file her 12 objection to Defendant’s Bill of Costs [ECF No. 203] and her response to Defendant’s Motion for 13 Attorneys’ Fees [ECF No. 204] and Defendant’s counsel agreed to stipulate to the requested 14 extensions. 15 3. Based on the foregoing, the parties stipulate to extend Plaintiff’s deadline to file her 16 objection to Defendant’s Bill of Costs [ECF No. 203] and her response to Defendant’s Motion for 17 Attorneys’ Fees [ECF No. 204] to April 2, 2024 and April 5, 2024 respectively. 18 4. This stipulation for an extension is brought in good faith, establishing good cause, 19 and is not sought for any improper purpose or other purpose of delay. Plaintiff’s counsel is 20 requesting this stipulated extension to provide Plaintiff’s counsel with sufficient time in light of 21 Plaintiff’s counsel’s need to take time off work to rest and recover after trial in this case. Counsel 22 was recently hospitalized in February, 2024 and has also been recovering from another illness 23 counsel was suffering from before and during trial in this case causing flu symptoms and preventing 24 counsel from working. Counsel was also out of state February 22-26, 2024 and will be out of the 25 office for her daughter’s Spring Break vacation starting March 8, 2024 and returning on March 18, 26 2024. Plaintiff’s counsel therefore requested and received a stipulated extension of time for all of 27 this good cause shown. 28 5. Courts in the District of Nevada have routinely held that extensions of deadlines for 1 illness and the “practicalities of life” establish good cause for the requested extension. Morales v. 2 McDaniel, 2019 U.S. Dist. LEXIS 173103 (D. Nev. Oct. 3, 2019). 3 6. These extensions of time are not sought for any improper purpose or other purpose of 4 delay. Rather, they are sought to allow the deadlines, which all fall on the same date while 5 Plaintiff’s counsel is out of the country and relying on cruise ship Wi-Fi, to be staggered to two 6 different dates in April to provide sufficient time for counsel for Plaintiff to prepare and file her 7 objection to bill of costs and response to motion for attorneys’ fees due to her illness during and after 8 trial, out of state travel, prior issues with cruise ship Wi-Fi, and her daughter’s Spring Break 9 vacation from March 8-17, 2024. 10 7. Through this stipulation, Plaintiff requests that the Court extend the deadline for 11 Plaintiff to file her objection to Defendant’s Bill of Costs from the current deadline of March 12, 12 2024 until April 2, 2024 and extend her deadline to file her response to Defendant’s Motion for 13 attorneys’ Fees from the current deadline of March 12, 2024 until April 5, 2024. 14 15 16 17 18 19 20 21 22 23 24 25 / / / 26 / / / 27 / / / 28 1 WHEREFORE, the parties respectfully request that the Court extend the deadlines as 2 || stipulated to and requested herein. 3 DATED this 8% day of March, 2024. 4 5 MELANIE HILL LAW PLLC KAMER ZUCKER ABBOTT 6 . . . . By: /s/ Melanie A. Hill By: /s/ Kaitlin H. Paxton 7 Melanie A. Hill, Esq. (NV Bar No. 8796) R. Todd Creer (NV Bar No. 10016) 1925 Village Center Circle, Ste. 150 Kaitlin H. Paxton (NV Bar No. 13625) 8 Las Vegas, Nevada 89134 6325 South Jones Blvd., Suite 300 Telephone: (702) 362-8500 Las Vegas, Nevada 89118 9 Facsimile: (702) 362-8505 Telephone: (702) 259-8640 10 Melanie@MelanieHillLaw.com Facsimile: (702) 259-8646 Attorneys for Plaintiff Pamela Dittmar tcreer@kzalaw.com 11 kpaxton@kzalaw.com Attorneys for Defendant City of North 12 Las Vegas 13 14 15 16 17 IT IS SO ORDERED. 18 yf tee AN DATE UNITED STATES DJSTRIC | JUDGE 20 21 22 23 24 25 26 27 28

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