Harris v. City of Henderson et al

Filing 15

ORDER Granting 14 Stipulation to Extend Time to Respond to 12 Motion to Dismiss. Responses due by 6/1/2015. Signed by Chief Judge Gloria M. Navarro on 5/27/2015. (Copies have been distributed pursuant to the NEF - DC)

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CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
C.J. POTTER, IV, ESQ.
Nevada Bar No. 13225
POTTER LAW OFFICES
1125 Shadow Lane
Las Vegas, Nevada 89102
Tel: [phone]
Fax: [phone]
JAY A. KENYON, ESQ.
Nevada Bar No. 6376
YAN KENYON
7881 West Charleston Boulevard #165
Las Vegas, Nevada 89117
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HARVESTER HARRIS,

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Plaintiff,
Case No. 2:15-cv-00337-GMN-PAL

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vs.

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CITY OF HENDERSON; a
political subdivision of the State of
Nevada; LAS VEGAS METROPOLITAN
POLICE DEPARTMENT, a political
subdivision of the State of Nevada;
SHERIFF DOUG GILLESPIE, individually;
CHIEF PATRICK MOERS, individually;
DOE OFFICER I, individually; DOE OFFICER II,
individually; DOE OFFICERS III-X;
and JOHN DOES I-X, inclusive,

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Defendants.
________________________________________/

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STIPULATION AND ORDER TO EXTEND PLAINTIFF’S

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RESPONSE TO DEFENDANTS’ MOTION TO DISMISS

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(First Request)

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Pursuant to LR 6-1 and LR 26-4, Plaintiff, HARVESTER HARRIS, by and through his

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counsel of record, CAL J. POTTER, III, ESQ. and C. J. POTTER, IV, ESQ. of POTTER LAW

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OFFICES, and Defendants CITY OF HENDERSON and CHIEF PATRICK MOERS, by and

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through their counsel of record, NANCY D. SAVAGE, ASSISTANT CITY ATTORNEY of the

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CITY OF HENDERSON, hereby stipulate and make a joint application to extend the Plaintiff’s

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Response to Motion to Dismiss in this matter.

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1.

Defendants filed a Motion to Dismiss [doc. 12] on May 4, 2015;

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2.

The current deadline to file a Response is May 21, 2015;

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3.

The Plaintiff seeks an eleven (11) day extension to file the Response up to and

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including Monday, June 1, 2015, which is the deadline for Plaintiff to file to

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Response to LVMPD’s Motion to Dismiss [doc. 13];

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4.

The parties submit that good cause exists for this extension as Plaintiff’s counsel has

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had approximately three (3) appellate briefs due since the filing of Defendants’

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Motion and has been unable to complete the Response;

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5.

This is the first request for enlargement of time and is made in good faith and not for
the purposes of delay.

APPROVED AS TO FORM AND CONTENT.

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DATED this 21st day of May, 2015.

DATED this 21st day of May, 2015.

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POTTER LAW OFFICES

CITY OF HENDERSON

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By
/s/ Cal J. Potter, III, 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/ Nancy D. Savage, Esq.
NANCY D. SAVAGE, ESQ.
Nevada Bar No. 392
240 Water Street
Las Vegas, Nevada 89101
Attorney for Defendants City of Henderson
and Chief Moers

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IT IS SO ORDERED.
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________________
DATED

IT IS SO ORDERED.
IT IS SO ORDERED.
________________________________
ORDER M. Navarro, Chief Judge
Gloria
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United States District Court
Gloria M. Navarro, Chief Judge
DATED: 05/27/2015
United States District Court
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UNITED STATES DISTRICT COURT JUDGE

DATED: 05/27/2015
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