Garay v. City of Las Vegas

Opinion

Nina Perales (pro hac vice) Ernest I. Herrera (pro hac vice) Luis L. Lozada (pro hac vice) MEXICAN AMERICAN LEGAL DEFENSE 634 South Spring Street, 11th Floor Los Angeles, CA 90014 Telephone: (213) 629-2512 Facsimile: (213) 629-0266 Email: nperales@m aldef.org eherrera@maldef.org llozada@maldef.org F.Travis Buchanan, Esq. NV Bar No. 9371 F.TRAVIS BUCHANAN, ESQ., & ASSOC., PLLC 701 East Bridger, Suite 540 Las Vegas, NV 89101 Telephone: (702) 331-5478 Facsimile: (702) 629-6919 Email: FtbLaw@gmail.com Attorneys for Plaintiffs D ISTRICT OF NEVADA ALICIA INES MOYA GARAY, JUAN Case No.: 2:20-cv-00119-GMN-EJY JAIME LOPEZ-JIMENEZ, and ARRIBA LAS VEGAS WORKER CENTER, STIPULATION AND [PROPOSED] ORDER TO EXTEND SCHEDULING DEADLINES Plaintiffs, (FIFTH REQUEST) vs. STATES IMMIGRATION AND CUSTOMS ENFORCEMENT, et al., Defendants. Under LR IA 6-1 and LR 26-3, the Parties, by and through their respective counsel of record, stipulate and request that this Court extend the Scheduling Deadlines in the above- captioned case. Plaintiffs Alicia Ines Moya Garay, Juan Jaime Lopez-Jimenez, and Arriba Las Vegas Worker Center (“Plaintiffs”) and Defendants City of Las Vegas, United States Immigration and Customs Enforcement, et al. (“Defendants”) stipulate and respectfully request a ninety-day extension of the current scheduling order deadlines. In support of this Stipulation and Request, the Parties state as follows: A. DISCOVERY COMPLETED TO DATE Plaintiffs Alicia Ines Moya Garay, Juan Jaime Lopez-Jimenez, and Arriba Las Vegas Worker Center (“Plaintiffs”) propounded written discovery on Defendan t United States Customs and Immigration Enforcement, et al. (“Federal Defendants”) on August 20, 2025. Plaintiffs propounded written discovery on Defendant City of Las Vegas, et al. (“City Defendants”) on August 27, 2025. Plaintiff met and conferred with Federal Defendants to resolve issues concerning sensitive and confidential information in September 2025. Plaintiffs received City Defendants’ responses to written discovery and City Defenda nts received Plaintiffs’ responses in September 2025. On October 2, 2025, the Court granted a stay of the case in light of lapse of appropriations. Dkt. 165. The Court lifted the stay on December 2, 2025. Dkt. 168. The Parties resumed discussions in resolving discovery responses and document production issues following the unavailability of counsel and holiday season. On January 14, 2026, Plaintiff Arriba received Federal Defendants’ responses to written discovery. Federal Defendants indicated the need for a protective order to produce responsive documents. On March 12, 2026, the Court granted the protective order. Dkt. 174. On February 20, 2026, City Defendants received Plaintiffs Garay’s and Lopez-Jimenez’s City Defendants received Plaintiff Arriba’s supplemental responses to written discovery. On June 30, 2026, Plaintiffs received City Defendants’ supplemental responses and supplemental initial disclosures. On May 14, 2026, Federal Defendants received Plaintiff Arriba’s responses and document production to written discovery. On May 15, 2026, Plaintiff Arriba received Federal Defendants’ document production. B. DISCOVERY REMAINING TO BE COMPLETED The Parties are still meeting and conferring regarding outstanding written discovery requests and document production. Federal Defendants requested supplemental responses from Plaintiff Arriba on July 8, 2026. On July 8, 2026, Plaintiffs sent a t hird set of requests for admissions and interrogatories to City Defendants, and Plaintiff Arriba sent a first set of interrogatories and requests for admission to Federal Defendants. Plaintiffs sent 30(b)(6) deposition notices to Defendants on July 17, 2026. The Parties met and conferred on July 23, 2026, and the parties agreed to provide supplemental responses and find other dates for noticed depositions. The Parties hope to resolve any rem aining issues without court intervention. The Parties seek an extension of the scheduling deadlines. An extension of dates and deadlines requires good and just cause. See LR 26-3. A party may show good cause to modify a schedule date “if it cannot reasonably be met despite the diligence of the party seeking the extension.” See Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992). Prejudice to “the party opposing the modification” may also be relevant. See id. Plaintiffs met and conferred with City Defendants and Federal Defendants on July 23, 2026. The Parties agreed to resolve pending discovery issues, but with the current discovery further meet and confer to resolve any discovery issues. Additionally, the parties agreed to find dates for depositions other than the dates noticed due to counsel unavailability. Because the Parties are meeting and conferring in good faith, and Defendants do not oppose an extension of the scheduling deadlines, the Parties demonstrate good and just cause for the extension. Further, good cause is shown by the lack of dilatory motive and good faith efforts to move this matter forward. Indeed, counsel for the Parties have been working diligently to respond to discovery requests and to cooperate in meet and confer efforts to avoid the need for law and motion related to discovery. The Parties respectfully request a ninety-day extension of the current scheduling order deadlines in accordance the proposed scheduling order below. The short extension of discovery and scheduling order deadlines is not for an y improper purpose or unnecessary delay. The Parties further offer that the proposed 90-day extension will not unduly affect the Court’s calendar or substantially delay the resolution of this matter. D. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 1.Discovery Cut-Off Date November 5, 2026 2.Dispositive Motions Due December 21, 2026 3.All Other Motions Due January 7, 2027 4.Pretrial Order (no dispositive motion filed) February 8, 2027 [stipulation continues on the next page] 5.Pretrial Order (dispositive motion filed) 30 days after decision 6.Pretrial Conference* February 22, 2027 7.Jury Trial (City Defendants)* (estimated 2 weeks) March 29, 2027 8.Bench Trial (Federal Defendants)* (estimated 2 weeks) March 29, 2027 *Subject to change if a dispositive motion is filed and a decision is pending. Dated: July 24, 2026 MEXICAN AMERICAN LEGAL DEFENSE JEFF M. DOROCAK AND EDUCATIONAL FUND Las Vegas City Attorney /s/ Luis L. Lozada /s/ Paul Mata Luis L. Lozada Deputy City Attorney Ernest I. Herrera NV Bar No. 14922 MEXICAN AMERICAN LEGAL DEFENSE 495 South Main Street, 6th Floor AND EDUCATIONAL FUND Las Vegas, NV 89101 634 South Spring Street, 11 Floor Los Angeles, CA 90014 Attorneys for City Defendants Telephone: (213) 629-2512 F. Travis Buchanan, Esq. U.S. DEPARTMENT OF JUSTICE NV Bar No. 9371 Office of Immigration Litigation F. TRAVIS BUCHANAN, ESQ., & ASSOC., PLLC /s/ Matthew P. Seamon 701 East Bridger, Suite 540 Assistant Director Las Vegas, NV 89101 P.O. Box 868, Ben Franklin Station Telephone: (702) 331-5478 Washington, D.C. 20044 Attorneys for Plaintiffs Attorneys for Federal Defendants IT IS SO ORDERED. ____________________________________ UNITED STATES MAGISTRATE JUDGE DATED: July 25, 2026