Nickler v. County of Clark et al

Filing 94

ORDER Granting 93 Second Stipulation for Extension of Time to File Joint Status Report. Joint Status Report due by 9/13/2019. Signed by Magistrate Judge Daniel J. Albregts on 8/30/2019. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:14-cv-01907-JCM-DJA Document 93 Filed 08/29/19 Page 1 of 2

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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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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
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
***
)
JACQUELYNN NICKLER,
)
)
) Case No.: 2:14-cv-01907-JCM-DJA
Plaintiff,
)
)
vs.
)
STIPULATION AND [PROPOSED]
)
ORDER TO EXTEND TIME TO FILE
COUNTY OF CLARK, organized and of the )
JOINT STATUS REPORT
existing under the laws of State of Nevada;
)
STEVEN D. GRIERSON, court administrator, )
individually; KATHLEEN LAMBERMONT, )
[SECOND REQUEST]
)
administrator of the Clark County District
)
Attorney’s office, individually; and, DOE 1
)
through 10, inclusive;
)
)
Defendants.

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COME NOW the Parties by and through their respective counsel of record, and hereby
stipulate and agree, and ask for the court’s approval, to extend the deadline to file the Joint Status

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Report ordered by Magistrate Judge Hoffman on August 2, 2019 for AN ADDITIONAL two weeks,

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from August 30, 2019 through and including September 13, 2019. The reason for this request is

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that the parties have continued to be tied up with other matters, especially including counsel for

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Plaintiff being focused on preparation for trial that was scheduled with Judge Dorsey for August 2724
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30 and only settled on the eve of trial on August 26. As a result of that Plaintiff’s counsel is now

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required to prepare for and travel to Washington State for deposition in a case on which he was just

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admitted pro hac vice in the Central District of California. There are additional depositions in that

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Case 2:14-cv-01907-JCM-DJA Document 93 Filed 08/29/19 Page 2 of 2

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case in Los Angeles on September 3 and September 6. Because of this unusually busy schedule

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Plaintiff’s counsel has been unable to meet and confer with Defense Counsel in this matter to

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formulate the Joint Status Report and it is not expected that this can take place until at least

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September 7 or September 8.
This extension of the deadline to file a Joint Status Report is sought in good faith and not for

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the purpose of delay.

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Dated: August 29, 2019

Dated: August 29, 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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ATTORNEYS AT LAW
7435 W. Azure Drive, Suite 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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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

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ORDER
IT IS SO ORDERED.

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______________________________________
DISTRICTAlbregts
Daniel J. JUDGE/MAGISTRATE JUDGE
United States Magistrate Judge
Dated: _________________________________
Dated: August 30, 2019

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