Michael Leon Williams v. State of Nevada, et al.

• Court: District Court, D. Nevada
• Decided: November 17, 2025
• Docket: 3:22-cv-00430
• Status: Unknown

Opinion

Attorney General 2 SAMUEL L. PEZONE JR. (Bar No. 15978) Deputy Attorney General 3 State of Nevada Office of the Attorney General 4 1 State of Nevada Way, Suite 100 Las Vegas, Nevada 89119 5 (702) 486-4070 (phone) (702) 486-3768 (fax) 6 Email: spezone@ag.nv.gov 7 Attorneys for Defendants John Keast and Melissa Mitchell 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 MICHAEL LEON WILLIAMS, Case No. 3:22-cv-00430-CLB 12 Plaintiff, ORDER GRANTING STIPULATION 13 v. TO EXTEND THE TIME TO FILE DEFENDANTS’ REPLY IN 14 STATE OF NEVADA, et al., SUPPORT OF ECF NO. 75 15 Defendants. (FIRST REQUEST) 16 Plaintiff, Michael Leon Williams, by and through counsel, Andre M. Lagomarsino, 17 and Taylor M. Jorgensen, of Lagomarsino Law, and Defendants, John Keast and Melissa 18 Mitchell, by and through counsel, Aaron D. Ford, Nevada Attorney General, and Samuel 19 L. Pezone Jr., Deputy Attorney General, of the State of Nevada, Office of the Attorney 20 General, hereby stipulate and agree to extend the time to file Defendants’ Reply in Support 21 of their Motion for Summary Judgement (ECF No. 75). This is the parties’ first request for 22 an extension of this deadline. There is good cause for this Court to grant an extension. 23 MEMORANDUM OF POINTS AND AUTHORITIES 24 I. LEGAL STANDARD 25 Pursuant to Fed. R. Civ. P. 6(b), the “court may, for good cause, extend the time . . . 26 with or without motion or notice . . . if a request is made, before the original time or its 27 extension expires,” or “on motion made after the time has expired if the party failed to act 28 because of excusable neglect.” 2 the exercise of due diligence, [the party was] unable to meet the” subject deadline. Cruz v. 3 City of Anaheim, CV-1003997-MMM-JEMX, 2011 WL 13214312, at *2 (C.D. Cal. Dec. 19, 4 2011) (citing Zivkovic v. Southern California Edison Co., 302 F.3d 1080, 1087 (9th Cir. 5 2002); Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)). Prejudice 6 to the opposing party is a factor in determining good cause, though lack of prejudice is “not 7 a prerequisite.” Id. 8 II. ARGUMENT 9 The parties request an extension of the deadline to reply in support of Defendants’ 10 Motion for Summary Judgment (ECF No. 75). Pursuant to LR 7-2(b), the deadline to file 11 this reply is November 18, 2025. Based upon the foregoing, there is good cause to extend 12 this deadline by seven (7) days, or until November 25, 2025. 13 Counsel for Defendants sustained a large second degree burn to his left thigh while 14 attempting to steep a pot of tea in his office on November 5, 2025. Counsel was triaged at 15 the University Medical Center (UMC) that day, and counsel has since attended several 16 outpatient appointments with UMC’s Burn and Wound Clinic. Due to these appointments 17 and the need to perform daily dressing changes, Defendants’ counsel has been 18 intermittently out of office since November 6, 2025, which has prevented counsel from 19 making any substantial progress in drafting Defendants’ reply brief in support of their 20 Motion for Summary Judgment. 21 A one-week extension should allow Defendants’ counsel adequate time to finalize 22 Defendants’ reply brief. The parties maintain that they will not be prejudiced by this short 23 extension. Accordingly, the parties respectfully request that this extension be granted for 24 good cause shown. See Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1260 (9th Cir. 25 2010) (holding that the “district court abused its discretion in denying party’s timely 26 motion” to extend time because the party “demonstrated the ‘good cause’ required by Rule 27 6, and because there was no reason to believe that [the party] was acting in bad faith or 28 was misrepresenting his reasons for asking for the extension”). 1 CONCLUSION 2 Based on the foregoing, there is good cause to extend the reply brief deadline. The 3 || parties respectfully request that this Court extend the deadline to file Defendants’ Reply 4 Support of ECF No. 75 until November 25, 2025. 5 |} DATED this 17th day of November, 2025. DATED this 17th day of November, 2025. 6 || AARON D. FORD 7 Attorney General /s/ Samuel L. Pezone, Jr. /s/ Taylor N. Jorgensen 8 ||Samuel L. Pezone, Jr. (Bar No. 15978) Andre M. Lagomarsino (Bar No. 6711) Deputy Attorney General Taylor N. Jorgensen (Bar No. 16259) 9 3005 W. Horizon Ridge Pkwy., No. 241 Attorneys for Defendants Henderson, Nevada 89052 10 (702) 383-2864 (phone) u Attorneys for Plaintiff 12 ORDER 13 IT IS SO ORDERED. . A Dated: November 17, 2025. 15 UNITED STATES\MAGISTRATE JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28