Friedman v. United States of America

Opinion

1]| LisA A. RASMUSSEN, ESQ. Nevada Bar No. 7491 2 || LAW OFFICE OF LISA RASMUSSEN, P.C. 601 South 10" Street, Suite #100 3 || Las Vegas, NV 89101 Tel. (702) 471-1436 Fax. (702) 489-6619 5 Email: Lisa@LRasmussenLaw.com 6 || MELANIE A. HILL, Esq. Nevada Bar No. 8796 7 || MELANIE HILL LAW PLLC 520 S. 7 Street, Suite A 8 || Las Vegas, NV 89101 Tel. — (702) 362-8500 Fax. (702) 362-8505 10 Email: Melanie@MelanieHillLaw.com 11 || Attorneys for Plaintiff Scott Friedman 12 15 16 || SCOTT FRIEDMAN, an individual, Case No. 2:18-C V-000857-JCM-VCF 17 Plaintiff, STIPULATION TO EXTEND 18 PLAINTIFF’S DEADLINE TO OPPOSE v. DEFENDANT USA’S MOTION TO 19 DISMISS [ECF No. 199]AND DEFENDA UNITED STATES OF AMERICA; GENE M. USA’S DEADLINE TO REPLY, 20 || TIERNEY, individually and in his official capacity] _PLAINTIFF’S DEADLINE TO OPPOSE as an FBI Agent; MATTHEW A. ZITO, THE LVMPD DEFENDANTS’ MOTION individually and in his official capacity as an FBI TO DISMISS [ECF NO. 201] AND □□□□□ 22 | Agent; THAYNE A. LARSON, individually and MOTION TO STRIKE [ECF NO. 200] 5 in his official capacity as an FBI Agent; LAS 3 | VEGAS METROPOLITAN POLICE (First Request) 24 || DEPARTMENT; JOE LEPORE, P#6260, individually and in his official capacity as an 25 || officer of the LAS VEGAS METROPOLITAN 96 || POLICE DEPARTMENT; DARREN HEINER, P#2609, individually and in his official capacity as 27 || an officer of the LAS VEGAS METROPOLITAN 8 POLICE DEPARTMENT; JASON HAHN, 2 P#3371, individually and in his official capacity as

an officer of the LAS VEGAS METROPOLITAN 5 POLICE DEPARTMENT; TALI ARIK, an individual; JULIE BOLTON, an individual; and 3 || ARIK VENTURES, an entity formed by Tali Arik, 4 Defendants. 5 6 7 8 Counsel for Plaintiff, Melanie A. Hill of Melanie Hill Law PLLC and Lisa Rasmussen of La 9 || Office of Lisa Rasmussen, P.C., counsel for the United States, Greg Addington, and counsel fi 10 || Defendants Las Vegas Metropolitan Police Department, Joe Lepore, Darren Heiner, and Jason Hah Nick Crosby and Jackie Nichols, respectfully submit the following stipulation to extend the followi1 121 deadlines: 13 1) Plaintiff's deadline to oppose the United States’ Motion to Dismiss First Amend “4 Complaint [ECF No. 199] is being extended to October 10, 2019 from its current □□□□□□□ of October 4, 2019; 17 2) Defendant USA’s deadline to file its Reply is being extended to October 18, 2019 from 1 18 new deadline of October 17, 2019; 19 3) Plaintiffs deadline to oppose the LVMPD Defendants’ Motion to Dismiss First □□□□□ 20 Complaint [ECF No. 201] is being extended to October 12, 2019 from its current deadlit 21 of October 4, 2019; and 22 4) Plaintiffs deadline to oppose the LVMPD Defendants’ Motion to Strike [ECF No. 200] 23 being extended to October 12, 2019 from its current deadline of October 4, 2019. 24 This is the first request to extend these deadlines. The Stipulation is being filed and the: 25! extensions are being requested due to the availability of counsel and not for purposes of dela 26 Plaintiff's counsel’s illness with bronchitis and a double ear infection has kept her out of work <¢ week due to its severity. Mr. Friedman had oppositions due this week to four Motions to Dismiss ar 28 the LVMPD’s Motion to Strike. Two of the oppositions were prepared and filed by Ms. HIIl’s □

1 counsel, Ms. Rasmussen and Ms. Hill is seeking these extensions due to her illness that kept her fro 2 completing these oppositions. Ms. Hill agreed to extend the USA’s Reply deadline for an addition 3 4 day to take into account the Columbus Day federal holiday on October 14, 2019 and as a result tl 5 USA’s Reply deadline is also being extended to October 18, 2019. 6 The requested relief is not for purposes of delay, but to allow for the availability of counsel. 7 DATED this 4" day of October, 2019. 8 NICHOLAS TRUTANISH 9 United States Attorney MELANIE HILL LAW PLLC 10 By: /s/ Gregory Addington By: /s/ Melanie A. Hill 12 Assistant United States Attorney Nevada Bar No. 8796 Nevada Bar No. 6875 Attorneys for Plaintiff Scott Friedman 13 Attorneys for Defendant United States of America 14 15

17 By: /s/ Jacqueline Nichols JACQUELINE VICTORIA NICHOLS 18 Nevada Bar No. 14246 1 Attorneys for Las Vegas Metropolitan Police 9 Department, Jason Hahn, Darren Heiner, and 20 Joe Lepore 21 23 Dated October 9, 2019. 24 Ethos ¢ Atal WP 25 (TAMES C. MAHAN 26 UNITED STATES DISTRICT COURT JUDGE

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