Harris v. City of Henderson et al

Filing 19

ORDER Granting 18 Stipulation to Extend Time to Respond to 12 Motion to Dismiss. Reply due by 6/23/2015. Signed by Chief Judge Gloria M. Navarro on 6/9/2015. (Copies have been distributed pursuant to the NEF - DC)

JOSH M. REID
City Attorney
Nevada Bar No. 7497
NANCY D. SAVAGE
Assistant City Attorney
Nevada Bar No. 392
240 Water Street, MSC 144
Henderson, NV 89015
[phone] Telephone
[phone] Facsimile
[e-mail]
Attorneys for Defendants
CITY OF HENDERSON and
CHIEF PATRICK MOERS

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
CASE NO.: 2:15-CV-00337-GMN-PAL

HARVESTER HARRIS,
Plaintiff,
v.
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 IX, inclusive,
Defendants.

STIPULATON AND ORDER TO EXTEND TIME TO FILE DEFENDANTS REPLY IN
SUPPORT OF THEIR MOTION TO DISMISS
(First Request)
Pursuant to Local Rule 6-1, Plaintiff, HARVESTER HARRIS, by and through his
attorney Cal J. Potter, III, Esq., of the POTTER LAW OFFICES, and Defendants CITY OF
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HENDERSON and PATRICK MOERS (“HENDERSON Defendants”), by and through their
attorneys Josh M. Reid, City Attorney and Nancy D. Savage, Assistant City Attorney for
the CITY OF HENDERSON, hereby stipulate and make a joint application to extend the
time to file the HENDERSON Defendants’ Reply in support of their Motion to Dismiss in
this matter.
1. HENDERSON Defendants filed their Motion to Dismiss (Doc. 12) on May 4,
2015;
2. Plaintiffs filed their Opposition (Doc. 17) on June 1, 2015;
3. The Defendants are seeking a twelve (12) day extension to file the Reply, up to
and including Tuesday, June 23, 2015;
4. The parties submit that good cause exists for this extension as HENDERSON
Defendants’ counsel was out of state the week of June 1, 2015 and returned to
the office on June 8, 2015 to numerous matters which had previously been
scheduled.

As a result there is insufficient time for the HENDERSON

Defendants’ counsel to prepare a complete and adequate Reply to the Plaintiff’s
Opposition;
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5. This is the first request for enlargement of time for the HENDERSON
Defendants to file their Reply, which is being made in good faith and not for the
purposes of delay.
APPROVED AS TO FORM AND CONTENT.
DATED this 8th day of June, 2015.

POTTER LAW OFFICES

CITY OF HENDERSON
JOSH M. REID, City Attorney

/s/ Cal J. Potter
CAL J. POTTER, III, ESQ.
Nevada Bar No. 1988
1125 Shadow Lane
Las Vegas, Nevada 89102
Attorney for Plaintiff

/s/ Nancy D. Savage
JOSH M. REID, ESQ.
City Attorney
Nevada Bar No. 7497
NANCY D. SAVAGE, ESQ.
Assistant City Attorney
Nevada Bar No. 392
240 Water Street, MSC 144
Henderson, Nevada 89009
Attorney for Defendants

ORDER
9th
IT IS SO ORDERED this ______ day of June, 2015.

_______________________________________
UNITED STATES DISTRICT COURT JUDGE
___________________________
Gloria M. Navarro, Chief Judge
United States District Court

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