Filed: Oct. 15, 2018
Latest Update: Oct. 15, 2018
Summary: Stipulation to extend time to file the first amended petition (First stipulation) (Sixth request for extension) ECF Nos. 16, 17 JENNIFER A. DORSEY , District Judge . The parties hereby stipulate to a 45-day extension of time for Ms. Love to file her first amended petition or other related pleading, up to and including November 26, 2018. Ms. Love's counsel represents there are ongoing negotiations between Ms. Love and the Clark County District Attorney's office, on behalf of the State of N
Summary: Stipulation to extend time to file the first amended petition (First stipulation) (Sixth request for extension) ECF Nos. 16, 17 JENNIFER A. DORSEY , District Judge . The parties hereby stipulate to a 45-day extension of time for Ms. Love to file her first amended petition or other related pleading, up to and including November 26, 2018. Ms. Love's counsel represents there are ongoing negotiations between Ms. Love and the Clark County District Attorney's office, on behalf of the State of Ne..
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Stipulation to extend time to file the first amended petition
(First stipulation) (Sixth request for extension)
ECF Nos. 16, 17
JENNIFER A. DORSEY, District Judge.
The parties hereby stipulate to a 45-day extension of time for Ms. Love to file her first amended petition or other related pleading, up to and including November 26, 2018. Ms. Love's counsel represents there are ongoing negotiations between Ms. Love and the Clark County District Attorney's office, on behalf of the State of Nevada, which may result in a possible alternative resolution of this case. The current deadline for the amended petition is October 12, 2018.1 Ms. Love has moved for five extensions to date.2 Now, the parties stipulate to another 45-day extension.
Ms. Love's counsel represents that her first amended petition is complete and ready to be filed. However, Ms. Love has agreed to withhold filing the petition— with this Court's permission—unless and until negotiations fail to resolve the case.
Ms. Love's counsel submits that 45 days is the minimum time necessary to allow the parties to complete the negotiation process and, if negotiations result in a resolution of this case, to finalize the additional steps necessary to officially resolve the matter. If 45-days proves insufficient time, the parties will provide a status update to the court on this matter on November 26, 2018.
However, in the event that negotiations do not result in a resolution of this case, Ms. Love will promptly file her amended petition upon termination of negotiations.
The parties agree that this stipulation does not waive any procedural defenses or statute-of-limitations challenges that respondents may raise in this case. The parties also agree that this stipulation does not constitute respondents' agreement with any of Ms. Love's representations in this or any other court filing.
Therefore, if this court approves this stipulation, the deadline for Ms. Love to file her first amended petition is extended up to and including November 26, 2018. Alternatively, if negotiations are still ongoing, the parties will provide this court with a status update on November 26, 2018. If negotiations terminate without agreement, Ms. Love will promptly file her amended petition, without delay.
ORDER
IT IS SO ORDERED; the deadline for petitioner to file her First Amended Petition is extented nunc pro tunc 11/26/18. IT IS FURTHER ORDERED that petitioner's motion for fifth extension of this deadline [ECF No. 16] is GRANTED nunc pro tunc to 9/12/18.
