Nickler v. County of Clark et al

Filing 115

ORDER granting 114 Stipulation; Re: 103 Motion for Leave to File Document. Replies due by 11/21/2019. Signed by Magistrate Judge Daniel J. Albregts on 11/18/2019. (Copies have been distributed pursuant to the NEF - JM)

Case 2:14-cv-01907-JCM-DJA Document 114 Filed 11/14/19 Page 1 of 3

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JAMES P. KEMP, ESQUIRE
Nevada Bar No. 006375
KEMP & KEMP, ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110,
Las Vegas, NV 89130
[phone] tel./[phone] fax
[e-mail]
Attorney for Plaintiff JACQUELYNN NICKLER

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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JACQUELYNN NICKLER,

)
)
)
Plaintiff,
)
)
vs.
)
COUNTY OF CLARK, organized and of the )
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existing under the laws of State of Nevada;
STEVEN D. GRIERSON, court administrator, )
individually; KATHLEEN LAMBERMONT, )
)
administrator of the Clark County District
)
Attorney’s office, individually; and, DOE 1
)
through 10, inclusive;
)
)
Defendants.
.

Case No. 2:14-cv-01907-JCM-DJA
STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF
TO REPLY TO DEFENDANTS’
OPPOSITIONS TO MOTION
FOR LEAVE TO FILE
AMENDED COMPLAINT
(FIRST REQUEST)

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The parties, by and through their respective counsel, hereby stipulate to extend the

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time for Plaintiff to reply to the Defendants’ oppositions (ECF Nos. 108 and 109) to

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Plaintiff’s motion seeking leave to file a First Amended Complaint. (ECF No. 103) Also

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Defendants Clark County and Lambermont filed a separate Joinder to Defendant

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Grierson’s Opposition (ECF No. 112). The proposed extension is from the current due

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date of Thursday, November 14, 2019 through and including Thursday, November 21,
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2019.
This is the first request for an extension of this deadline. The parties provide the

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Case 2:14-cv-01907-JCM-DJA Document 114 Filed 11/14/19 Page 2 of 3

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following information to the Court regarding the proposed extension of time:

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1. Plaintiff’s counsel has informed Defense counsel that an extension to file

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the reply is needed because due to the Veterans Day holiday weekend, with

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a number of longstanding family plans and responsibilities there has been

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insufficient time for Plaintiff’s counsel to respond to the 19 page and 12

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page Oppositions and the five page Joinder;

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2. Plaintiff’s counsel has family in from Florida and Washington for a long

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planned family get together surrounding Plaintiff’s son playing in his Las

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Vegas Academy band concert at the Smith Center on Wednesday night,

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November 13, 2019.

These family members arrived on Saturday and

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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Tuesday respectively and the last of them do not leave until this coming

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Saturday.

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3. Additionally, Plaintiff’s counsel has had a very heavy workload in this

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period. On November 12 he had a morning hearing in state court and an

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afternoon deposition in another cases against Clark County at the office of

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Mr. Freeman (opposing counsel in this matter for Clark County and

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Lambermont). Then on Wednesday, November 13 Plaintiff’s counsel had

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a lengthy settlement conference with Magistrate Judge Albregts followed

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by an administrative Workers’ Compensation appeal hearing and then

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several client meetings.

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opposing a Summary Judgment Motion, the opposition being due on

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Monday, November 18, 2019.

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Thursday, November 14 must be devoted to

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Case 2:14-cv-01907-JCM-DJA Document 114 Filed 11/14/19 Page 3 of 3

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This stipulation to extend the deadline is made in good faith and not for purposes of
delay.
Dated: November 14, 2019

Dated: November 14, 2019

/s/
James P. Kemp
James P. Kemp, Esq.
KEMP & KEMP ATTORNEYS AT LAW
7435 West Azure Drive, Suite 110
Las Vegas, NV 89130
[phone]/ 258-6983 fax
Attorney for Plaintiffs

/s/
Robert W. Freedman, Jr.
Robert W. Freedman, Jr., Esq.
LEWIS BRISBOIS BISGAARD & SMITH
6385 S. Rainbow Blvd., Ste. 600
Las Vegas, NV 89118
[phone] / [phone] fax
[e-mail]
Attorneys for Defendants Clark County and
Kathleen Lambermont

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/s/ D. Randall Gilmer
D. Randall Gilmer, Esq.
OFFICE OF ATTORNEY GENERAL
555 E. Washington Avenue, Suite 2600
Las Vegas, NV 89101
[phone] / [phone] fax
[e-mail]
Attorney for Steven D. Grierson

ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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IT IS SO ORDERED:

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MAGISTRATE JUDGE

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November 18, 2019
Dated:______________________________

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