Britain et al v. Clark County, Nevada

Filing 112

ORDER Granting 110 Stipulation to Extend the TIme for Filing the Joint Pre-Trial Order. Proposed Joint Pretrial Order due by 7/29/2015. Signed by Judge Jennifer A. Dorsey on 4/23/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:12-cv-01240-JAD-NJK Document 110 Filed 04/22/15 Page 1 of 3

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Robert W. Freeman, Jr., Esq.
Nevada Bar No. 003062
LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
702-893-3383
Attorneys for Defendant
Clark County

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UNITED STATES DISTRICT COURT
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CLARK COUNTY, NEVADA

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*****

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TRINA BRITAIN, KARL BEAVERS,
RONALD BROOKS, BRET CEGAVSKE,
BILLY CRANK, DENNIS CURRAN, KEVIN
ECKHART, KENNETH HAWKES, RANDY
HAWKES, IAN MASSY, RIC MOON,
GRAJEDA NUBIA, MICHAEL PETTY,
KAREN PIXLER, ERIC PRUNTY,
ANTHONY RUSSO, TOM SERRANO,
ANTHONY SMITH, MICHAEL SMITH,
ENRIQUE STIEGELMEYER, ANTHONY
VOGEL, and LAMONS WALKER,

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Plaintiff,

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vs.

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CLARK COUNTY, NEVADA,

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Defendant.

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CASE NO: 2:12-cv-01240-JAD-NJK
STIPULATION AND ORDER TO
EXTEND THE TIME FOR FILING
THE JOINT PRE-TRIAL ORDER
(First Request)

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IT IS HEREBY STIPULATED between the parties, by and through their respective
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LEWIS
BRISBOIS
BISGAARD

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counsel, that the parties shall have an additional ninety (90) days in which to file their Joint PreTrial Order. The Joint Pre-Trial Order is currently due on April 30, 2015.
The extension is requested and based on the following:
Robert W. Freeman, counsel for defendants has been involved in multi day out of state

Case 2:12-cv-01240-JAD-NJK Document 110 Filed 04/22/15 Page 2 of 3

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depositions during the month of April 2015 in Hackler v. State Farm, 3:14-cv-0531-MMD-VPC.
Further depositions in this matter are expected to continue through late May and early June. In

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addition counsel for defendants is involved in preparing a motions for summary judgment in
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Graham v. City of North Las Vegas, 2:13-cv-1818-KJD-VCF and Plank v. Mayoral, 2:12-cv-2205JCM-PAL. In addition counsel is preparing an opening brief in Koiro v. Catanese, 14-17514.

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Finally, counsel for defendants in preparing for trial in Schwartz v. GEICO, A594541, set
to begin June 22, 2015.

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Counsel for plaintiffs counsel just finished a three (3) day hearing before the Employee
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Management Relations Board (“EMRB”) in O’Leary v Las Vegas Metropolitan Police

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Department, EMRB Case No. A1-046116 and is currently preparing for back to back cases before

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the EMRB in NCLEA v Nye County, EMRB Case No. A1-046123 and ESEA/POA of CCSD v

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Clark County School District, EMRB Case No. A1-046113 which are scheduled to begin on June

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9, 2015.
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In addition, counsel for plaintiff’s wife was hospitalized on February 17, 2015 with a life

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threatening cardiac condition which has limited his availability.

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The additional time will allow the parties the necessary time to prepare the Joint Pre-Trial
Memo.

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Based on the foregoing, the parties request that this Court order the time for to file the Joint
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Pre-Trial order be extend ninety (90) days up to and including July 29, 2015.

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LEWIS
BRISBOIS
BISGAARD

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Case 2:12-cv-01240-JAD-NJK Document 110 Filed 04/22/15 Page 3 of 3

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The parties acknowledge that this stipulation is made in good faith and not for purposes of

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delay.
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DATED this 22nd day of April, 2015.

DATED this 22nd day of April, 2015.

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LEWIS BRISBOIS BISGAARD & SMITH

LAW OFFICE OF DANIEL MARKS

/s/ Robert W. Freeman
Robert W. Freeman, Esq.
Nevada Bar No. 3062
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendant
Clark County

/s/ Adam Levine
Adam Levine, Esq.
Nevada Bar No. 4673
610 S. Ninth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiffs

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ORDER
IT IS SO ORDERED.

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Dated this _____ day of ________, 2015.
Dated: April 23, 2015.
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______________________________
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U.S. DISTRICT COURT JUDGE
DISTRICT COURT JUDGE
S. DI
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D

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LEWIS
BRISBOIS
BISGAARD

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