Thomas Supranovich v. Juan Julio, et al.

Attorney General 2 NATHAN M. CLAUS (Bar No. 15889) 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) 486-7629 (phone) (702) 486-3768 (fax) — 6 — Attorneys for Defendants, 7 James Dzurenda, John Julio, Gabriela Najera, Karissa Currier, 8 and Melvin Henderson 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 THOMAS SUPRANOVICH, Case No. 2:24-cv-00979-JAD-NJK 12 Plaintiff, DEFEDANTS’ MOTION FOR 13 v. EXTENSION OF TIME TO FILE A RESPONSE TO PLAINTIFF’S 14 JUAN JULIO, et al., MOTION TO COMPEL ECF NO. 26 15 Defendants. [FIRST REQUEST] 16 Defendants, James Dzurenda, John Julio, Gabriela Najera, Karissa Currier, and 17 Melvin Henderson, by and through Aaron D. Ford, Attorney General for the State of 18 Nevada, and Nathan M. Claus, Deputy Attorney General, hereby submit this motion for 19 extension of time to file a response to Plaintiff’s Motion to Compel. ECF No. 26. This is the response 20 first request and is only for seven days, making the proposed reply date January 9, 2026. 21 MEMORANDUM OF POINTS AND AUTHORITIES 22 I. PROCEDURAL HISTORY 23 Plaintiff Thomas Supranovich sues James Dzurenda, John Julio, Gabriela Najera, 24 Karissa Currier, and Melvin Henderson for alleged events that took place while he was 25 incarcerated at Southern Dessert Correctional Center. ECF No. 4. 26 Plaintiff filed a motion to compel seeking production of documents. ECF No. 26. 27 Responses to this motion are due on January 2, 2026. Id. 28 /// 2 trips by counsel during December 22, 2025, through January 3, 2026, which will cause him to 3 have limited access to his documents needed to respond to this motion. 4 II. ARGUMENT 5 Motions to extend deadlines set out in a discovery plan or scheduling order are 6 governed by Fed. R. Civ. P. 16(b)(4) and LR 26-3. To prevail on a motion to extend a 7 scheduling order deadline, the moving party must show “good cause.” Id. 8 To demonstrate good cause, the parties must show “that, even in the exercise of due 9 diligence, [the parties were] unable to meet the timetable set forth in the order.” Cruz v. 10 City of Anaheim, CV-1003997-MMM-JEMX, 2011 WL 13214312 , at *2 (C.D. Cal. Dec. 19, 11 2011) (citing Zivkovic v. Southern California Edison Co., 302 F.3d 1080, 1087 (9th Cir. 12 2002); Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992)). Prejudice 13 to the opposing party is a factor in determining good cause, though lack of prejudice is “not 14 a prerequisite.” Id. 15 Counsel for Defendants has two preplanned trips to see family over the Christmas 16 and New Years holidays.1 During this time, counsel will be responding to emails 17 sporadically but will have difficulty responding to this motion because he will have limited 18 access to his documents needed to respond to this motion. 19 Good cause is present to extend the response deadline until January 9, 2026, because 20 of these preexisting trips. In addition, it would be burdensome for Defendants to have 21 another counsel from the Office of the Attorney General respond to this motion because 22 undersigned counsel is well aware of these facts and can fully respond to the opposition, 23 while it would take new counsel longer to learn the facts than for current counsel to 24 respond. The seven-day extension will not prejudice Plaintiff since this extension is minor 25 and will not delay this case too much. 26 Accordingly, Defendants respectfully request that the extension be granted for good 27 cause shown. See Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253 , 1260, (9th Cir. 2010) — 28 — 1 The specifics on the details of these trips can be provided to the court upon request. 1 || (holding that the “district court abused its discretion in denying party’s timely motion” to 2 ||extend time because the party “demonstrated the ‘good cause’ required by Rule 6, and 3 because there was no reason to believe that [the party] was acting in bad faith or was 4 || misrepresenting his reasons for asking for the extension”). 5 CONCLUSION 6 Based on the foregoing, and for good cause, Defendants request an extension of time 7 January 9, 2026, for them to file their replyin-support-of their motion for summary g || judement. response to the motion to compel. 9 DATED this 19th day of December, 2025. 10 AARON D. FORD Attorney General By: /s/ Nathan M. Claus 12 NATHAN M. CLAUS (Bar No. 15889) 13 Deputy Attorney General Attorneys for Defendants 15 || 1S SO ORDERED. 16 Dated: December 22, 2025 18 || Nancy JsKoppe 19 United States Magistrate Judge — 20 — — 21 — — 22 — — 23 — — 24 — — 25 — — 26 — — 27 — — 28 —