Nickler v. County of Clark et al

Filing 38

ORDER Granting 34 Stipulation for Extension of Time. Signed by Judge James C. Mahan on 4/16/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01907-JCM-CWH Document 34 Filed 04/07/15 Page 1 of 2

1 CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
2 C. J. POTTER, IV, ESQ.
Nevada Bar No. 13225
3 POTTER LAW OFFICES
1125 Shadow Lane
4 Las Vegas, Nevada 89102
Tel: [phone]
5 Fax: [phone]
Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JACQUELYNN NICKLER
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Plaintiffs,

CASE NO.: 14-cv-1907-APG-CWH

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vs.
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COUNTY OF CLARK, organized and of the
13 existing under the laws of State of Nevada;
STEVEN D. GRIERSON, court administrator,
14 individually; KATHLEEN LAMBERMONT,
administrator of the Clark County District
15 Attorney’s office, individually; and,
DOE 1 through 10, inclusive;
16
Defendants.
17 ________________________________________/
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STIPULATION AND ORDER TO EXTEND PLAINTIFF’S RESPONSE TO

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DEFENDANTS CLARK COUNTY AND LAMBERMONT’S JOINDER TO MOTION

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TO DISMISS AND TO EXTEND DEFENDANTS’ REPLY THERETO

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Pursuant to LR 6-1, Plaintiff, Jacquelynn Nickler, by and through her counsel of record

22 Cal J. Potter, III, Esq. and C. J. Potter, IV, Esq. of Potter Law Offices and Defendants, Clark
23 County and Kathleen Lambermont, by and through their counsel of record, Robert. W.
24 Freeman, Esq. and Cayla Witty, Esq. of Lewis Brisbois Bisgaard & Smith, hereby stipulate and
25 request that the scheduled date of filing of Plaintiff’s Response to Defendants Clark County
26 and Lambermont’s Joinder to Motion to Dismiss [doc. 18], previously extended to Thursday,
27 March 26, 2015 be extended six (6) days up to and including Monday, April 13, 2015. In
28 addition the parties seek that Defendants’ Reply thereto be extended to Friday, May 1, 2015.

Case 2:14-cv-01907-JCM-CWH Document 34 Filed 04/07/15 Page 2 of 2

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Plaintiff submits that good cause exists for this extension. Plaintiff previously extended

2 the Response [doc. 23], but at the time of filing and responding to the Motion [doc. 28]
3 Plaintiff’s counsel inadvertently failed to respond to the Joinder. Upon realizing the mistake,
4 Plaintiff’s counsel conferred with Defendants’ counsel who was amenable to a second
5 extension. Defendants also request an extension for their Reply.
6

Based upon the foregoing, the parties request that this Court order the time for the

7 Plaintiff to file her response to the Motion to Dismiss [doc. 12] and Joinder [doc. 18] to
8 Thursday, March 26, 2015. The parties also request that this Court provide a concomitant
9 enlargement of time for the Defendant’s Reply thereto.
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This is the second request for enlargement of time to file the Response and first request

11 for enlargement of time to file the Reply. These requests are made in good faith and not for the
12 purposes of delay.
13

APPROVED AS TO FORM AND CONTENT.

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DATED this 7th day of April, 2015.

DATED this 7th day of April, 2015.

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POTTER LAW OFFICES

LEWIS BRISBOIS BISGAARD & SMITH, LLP

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By: /s/ C. J. Potter, IV, Esq.
CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
C. J. POTTER, IV, ESQ.
Nevada Bar No. 13225
1125 Shadow Lane
Las Vegas, Nevada 89102
Attorneys for Plaintiff

By /s/ Robert W. Freeman, Esq.
ROBERT W. FREEMAN, ESQ.
Nevada Bar No. 3062
CAYLA WITTY, ESQ.
Nevada Bar No. 12897
6385 South Rainbow Boulevard, Ste. 600
Las Vegas, NV 89118
Attorney for Defendants Clark County and
Kathleen Lambermont

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ORDER

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IT IS SO ORDERED.

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Dated this ____ day of April, 2015.
April 16, 2015.

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_____________________________________
U.S. DISTRICT COURT JUDGE
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