KRISTEN FORBES-RAMIREZ as Special Administrator of the Estate of VICTOR

Opinion

Acting Attorney General of the United States First Assistant United States Attorney District of Nevada Nevada Bar No. 8264

NATHAN M. CLAUS Assistant United States Attorney Nevada Bar No. 15889 501 Las Vegas Blvd. So., Suite 1100 Las Vegas, Nevada 89101 (702) 388-6336 Nathan.Claus@usdoj.gov

Attorneys for the Federal Defendant

UNITED STATES DISTRICT COURT

KRISTEN FORBES-RAMIREZ as Special Case No. 2:24-cv-02290-GMN-BNW Administrator of the Estate of VICTOR RAMIREZ, deceased, Joint Motion and Request for Extension Plaintiff, of the Dispositive Motion Deadline v. [First Request] Defendant. Plaintiff Victor Ramirez and Defendant United States of America, by and through their respective counsel of record, hereby submit this joint Motion and Request for Extension of the Dispositive Motion Deadline. This is the first request. The dispositive motion deadline is currently July 9, 2026. ECF No. 22. After discussing the Defendant’s need for an extension of this deadline, the parties are requesting that this court extend that deadline by 32 days, making the new deadline August 10, 2026. FRCP 6(b) addresses extending time, stating:

(1) In General. When an act may or must be done within a specified time, the court may, for good cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires; or The proper procedure, when additional time for any purpose is needed, is to present the request for extension of time before time then fixed for purpose in question has expired. Canup v. Mississippi Val. Barge Line Co., 31 F.R.D. 282 (W.D. Pa. 1962). Extensions of time may always be asked for, and usually are granted on a showing of good cause if timely made under subdivision (b)(1) of the Rule. Creedon v. Taubman, 8 F.R.D. 268 (N.D. Ohio 1947). Good cause exists to enlarge the time by which a party may file a brief where additional time 1s needed to prepare such a brief. See O'Connor v. U.S. LR.S., 698 F. Supp. 204, 205 (D. Nev. 1988) (district court granted plaintiffs' motion for an extension of time to oppose a motion for summary judgment); Germaine Music v. Universal Songs of Polygram, 275 F. Supp. 2d 1288, 1301 (D. Nev. 2003) (district court granted movant's motion for additional time to oppose a motion for summary judgment, in part due to movant's need to acquire or prepare extensive documents so as to be able to adequately oppose the motion). Defendant will need 32 more days to submit the dispositive motion due to scheduling issues that have resulted in additional time needed to complete declarations from various National Park Service employees. Several of these employees no longer work in Nevada, so communications are taking longer than expected. Respectfully submitted this 9th day of July 2026. BREEDEN MALPRACTICE & TODD BLANCHE INJURY LAW Acting Attorney General SIGAL CHATTAH /s/ Adam J. Breeden, Esg First Assistant United States Attorney ADAM J. BREEDEN, Esq. 7432 W. Sahara Ave., Suite 101 /s/ Nathan M. Claus Las Vegas, NV 89117 NATHAN M. CLAUS Attorney for Plaintiff Assistant United States Attorney Attorneys for the United States of America IT IS SO ORDERED: Vf UNITED SPAITES DISTRICT JUDGE DATED: July 9, 2026