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Fernandez v. Jackson, 3:13-cv-670-RCJ-WGC. (2018)

Court: District Court, D. Nevada Number: infdco20181128f36 Visitors: 8
Filed: Nov. 27, 2018
Latest Update: Nov. 27, 2018
Summary: STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE (SECOND FINAL REQUEST) WILLIAM G. COBB , Magistrate Judge . Defendants by and through its counsel of record, Adam Paul Laxalt, Attorney General of the State of Nevada, and Erin L. Albright, Deputy Attorney General, and Plaintiff, Kevin Fernandez, by and through his counsel of record, Joseph Reiff, Esq., hereby stipulate to extend the time to file the Stipulation and Order of Dismissal with Pre
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STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE STIPULATION AND ORDER OF DISMISSAL WITH PREJUDICE (SECOND FINAL REQUEST)

Defendants by and through its counsel of record, Adam Paul Laxalt, Attorney General of the State of Nevada, and Erin L. Albright, Deputy Attorney General, and Plaintiff, Kevin Fernandez, by and through his counsel of record, Joseph Reiff, Esq., hereby stipulate to extend the time to file the Stipulation and Order of Dismissal with Prejudice by one week.

On September 18, 2018, defense counsel provided plaintiff's counsel with the revised settlement agreement that reflected the majority of the changes requested by Plaintiff. On the same date, plaintiff's counsel provided the settlement agreement to the New Hampshire prison for delivery to Plaintiff.

On October 29, 2018, defense counsel received Plaintiff's requested changes to the revised settlement agreement.

In early November 2018, the parties scheduled a conference call to finalize the terms of the settlement agreement. On November 13, 2018, the parties held a conference call and finalized the terms of the agreement. During this phone call, Plaintiff was advised that defense counsel would not return to the office until November 26, 2018. After the phone call, the revised agreement was promptly provided to Plaintiff.

On November 20, 2018, while defense counsel was out of the office, Plaintiff sent an email requesting additional changes to the settlement agreement.

On November 26, 2018, defense counsel reviewed Plaintiff's requested changes defense counsel and Plaintiff's counsel have scheduled to discuss the revisions as some but not all of the revisions can be made. Since the requested revisions are minor, the parties believe no more than a week is required to execute the settlement documents.

Since the settlement documents must be filed today and the parties will not have time to discuss and finalize the requested changes, the parties respectfully request this Court extend the deadline to file the Stipulation and Order of Dismissal to December 3, 2018.

IT IS SO ORDERED.

Source:  Leagle

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