Donatell v. City of Las Vegas et al

Filing 115

ORDER Granting 114 Stipulation for Extension of Time re 112 and 113 MOTIONS for Summary Judgment. Responses due by 10/16/2017. Signed by Judge Richard F. Boulware, II on 9/14/2017. (Copies have been distributed pursuant to the NEF - SLD)

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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, NV 89102
Ph: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JUDY DONATELL, individually; JUDY
DONATELL, as Special Administrator of
the Estate of ANGELA DAWN DONATELL,
deceased; JUDY DONATELL, as the Guardian
Ad Litem for X. M., a minor, under 14 years of
age,

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Plaintiffs,

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v.

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THE CITY OF LAS VEGAS, a political
subdivision of the State of Nevada; et al.

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Case No.: 2:15-cv-02334-RFB-NJK

STIPULATION AND ORDER TO
EXTEND PLAINTIFFS’ RESPONSE
TO DEFENDANT CITY OF LAS
VEGAS’ MOTION FOR SUMMARY
JUDGMENT [ECF 112] and
DEFENDANT CORRECT CARE
SOLUTIONS’ MOTION FOR
SUMMARY JUDGMENT [ECF 113]

Defendants.

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COMES NOW, the above-referenced parties, by and through their undersigned counsel

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of record, and hereby agree, jointly stipulate that the Plaintiffs’ Response to Defendant City of

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Las Vegas’ Motion Summary Judgment, filed on August 24, 2017 [ECF 112], currently due

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September 14, 2017, be extended an additional (30) thirty days up to and including Monday,

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October 16, 2017, and Plaintiffs’ Response to Defendant Correct Care Solutions’ Motion for

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Summary Judgment, filed on August 25, 2017 [ECF 113], currently due to September 15, 2017,

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be extended an additional (30) thirty days up to and including Monday, October 16, 2017.

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Although Plaintiffs’ counsel has been actively working on responding to Defendants'

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Motion, Plaintiffs’ counsel has been unable to complete the Responses due to a medical

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emergency.

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This request for extension is made in good faith and not for the purposes of delay.

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WHEREFORE, the parties respectfully request that Plaintiffs’ Response to City of Las

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Vegas’ Motion for Summary Judgment and the Response to Correct Care Solutions’ Motion for

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Summary Judgment, be extended an additional (30) thirty days up to and including Monday,

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October 16, 2017.

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APPROVED AS TO FORM AND CONTENT.

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Dated this 12th day of September, 2017.

Dated this 12th day of September, 2017.

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POTTER LAW OFFICES

LEWIS BRISBOIS BISGAARD & SMITH
LLP

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 Plaintiffs

By_/s/ Amanda J. Brookhyser, Esq.
S. Brent Vogel, Esq.
Nevada Bar No. 6858
Amanda J. Brookhyser, Esq.
Nevada Bar No. 11526
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendant
Correct Care Solutions

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Dated this 12th day of September, 2017.
LAS VEGAS CITY ATTORNEY
By__/s/ Philip R. Byrnes, Esq.
Bradford R. Jerbic, City Attorney
Nevada Bar No. 1056
Philip R. Byrnes, Snr. Litigation Counsel
Nevada Bar No. 166
495 South Main Street, 6th floor
Las Vegas, NV 89101
Attorneys for Defendant
City of Las Vegas and City of Las Vegas
Individual Defendants

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ORDER

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IT IS SO ORDERED.

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September
Dated this __ day of ______________, 2017.
14th

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________________________________
UNITED STATES DISTRICT JUDGE