STIPULATION AND ORDER TO EXTEND RESPONSE TO MOTION FOR SUMMARY JUDGMENT AND REPLY TO RESPONSE TO MOTION FOR PARTIAL SUMMARY JUDGMENT

(First Request)

GLORIA M. NAVARRO, Chief District Judge.

COMES NOW, the above-referenced parties, by and through their undersigned counsel of record, and hereby agree, jointly stipulate that the Plaintiff's Response to Defendants' Motion for Summary Judgment [ECF 36] filed on September 28, 2016, currently due October 24, 2016, and Plaintiff's Reply to Response to Plaintiff's Motion for Partial Summary Judgement [ECF 41] filed October 20, 2016, currently due October 27, 2016 be extended an additional fifteen (15) days up to and including Tuesday, November 8, 2016.

Although Plaintiff's counsel has been actively working on responding to Defendants' Motion and Reply to Response to Plaintiff's Motion, Plaintiff's counsel has been unable to complete the Response and the Reply. Since the filing of Defendants' Motion, Plaintiff's counsel has had nine (9) depositions; seven (5) preliminary hearings; seven (3) appellate briefs; a 9th Circuit Court Oral Argument in Beltran-Romero v. NDOC, case number 14-17204; preparing for a Jury Trial set to commence on October 24, 2016 in Kenneth Head adv. State of Nevada, case number C-13-294581-1, and numerous substantive motions and responses; as well as other general appearances and deadlines.

This request for extension is made in good faith and not for the purposes of delay.

WHEREFORE, the parties respectfully request that the Response and Reply to Response be extended an additional fifteen (15) days up to and including Tuesday, November 8, 2016.

APPROVED AS TO FORM AND CONTENT.

ORDER

IT IS SO ORDERED.