Donatell v. City of Las Vegas et al

Filing 133

ORDER Granting 130 Stipulation for Extension of Time Re: 112 Motion for Summary Judgment. Plaintiff's Responses due by 1/30/2018. Signed by Judge Richard F. Boulware, II on 1/25/2018. (Copies have been distributed pursuant to the NEF - SLD)

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SAO
MARJORIE HAUF, ESQ.
Nevada Bar No. 8111
JEFFREY GALLIHER, ESQ.
Nevada Bar No. 8078
GANZ & HAUF
8950 W. Tropicana, Suite 1
Las Vegas, NV 89147
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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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CASE NO.:

2:15-CV-02334-RFB-NJK

STIPULATION AND ORDER TO
EXTEND THE TIME FOR PLAINTIFF
TO FILE OPPOSITION TO
DEFENDANT CITY OF LAS VEGAS’
MOTION FOR SUMMARY
JUDGEMENT [ECF 112]
(FORTH REQUEST)

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

Defendants

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COMES NOW Plaintiff, JUDY DONATELL, INDIVIDUALLY; JUDY DONATELL, AS
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THE SPECIAL ADMINISTRATOR OF THE ESTATE OF ANGELA DAWN DONATELL

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DECEASED; JUDY DONATELL, AS THE GUARDIAN AD LITEM FOR X.M., A MINOR,

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UNDER 14 YEARS OF AGE (“Plaintiff”) and Defendants CITY OF LAS VEGAS, MICHELE

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FREEMAN, LIEUTENANT RUSSELL, SERGEANT AVILA, SERGEANT M. BUNNELL,

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SERGEANT B. BYARD, OFFICER R. DORADO, OFFICER AMANDA CHALMERS,
OFFICER TRACEY VALENZUELA, OFFICER A. KNIGHT, OFFICER JONATHAN

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McCORMICK, OFFICER ALGIN BROOKS, OFFICER RAMON BROOKINS, OFFICER
YANNIS GIRON, OFFICER LANDROVE, OFFICER BLEDSOE, OFFICER RANDALL

8950 W. Tropicana Ave., #1
Las Vegas, NV 89147
Phone: [phone]
Fax: [phone]

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(“Defendant City of Las Vegas), by and through their undersigned counsel of record, and hereby

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jointly stipulate that the Plaintiff’s Opposition to Defendant City of Las Vegas’ Motion for

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Summary Judgment, filed on August 24, 2017 [ECF 112], currently due January 2, be extended an
additional (30) days up to and including Tuesday, January 30, 2018.

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On November 3, 3017, this Court granted 60-day extension of time for Plaintiff to file her

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Oppositions to Defendant City of Las Vegas’ Motion for Summary Judgment [EFC 112] and

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Defendants Correct Care Solutions, et al.’s (“Defendant CCS”) Motion for Summary Judgment

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[EFC 113] to allow Plaintiff’s counsel to obtain the entire care file from the former counsel’s

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office. While the entire case file was obtained on or about December 4, 2017, and Plaintiff’s

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counsel diligently working on responding to Defendant City of Las Vegas’ Motion for Summary

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Judgment, Plaintiffs’ counsel has been unable to complete the Response due to a family tragedy.
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Plaintiff’s counsel, however, will timely file Plaintiff’s Opposition to Defendant CCS’ Motion for

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Summary Judgment. [EFC 113]

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8950 W. Tropicana Ave., #1
Las Vegas, NV 89147
Phone: [phone]
Fax: [phone]

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

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WHEREFORE, the parties respectfully request that Plaintiff’s Opposition to Defendant

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City of Las Vegas’ Motion for Summary Judgment be extended an additional (30) thirty days up to
including Tuesday, January 30, 2018.

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APPROVED AS TO FORM AND CONTENT.
Dated this 28th day of December 28, 2017.

Dated this 28th day of December 28, 2017.

GANZ & HAUF

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LAS VEGAS CITY ATTORNEY

/s/ Jeffrey L. Galliher
_____________________________
MARJORIE HAUF, ESQ.
Nevada Bar No. 8111
JEFFREY L. GALLIHER, ESQ.
Nevada Bar No. 8078
8950 W. Tropicana Ave., Ste. 1
Attorneys for PLAINTIFFS

/s/ Philip R. Byrnes
______________________________
PHILIP R. BYRNES, ESQ.
Nevada Bar No. 166
495 S. Main Street, 6th Floor
Las Vegas, Nevada 89101
Attorney for CITY DEFENDANTS

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ORDER

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IT IS SO ORDERED.

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___________________________________________
DATED this 25th day of January, 2018.
DATED
U.S. DISTRICT COURT JUDGE

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Submitted by:
GANZ & HAUF

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_____________________________
MARJORIE HAUF, ESQ.
Nevada Bar No. 8111
JEFFREY L. GALLIHER, ESQ.
Nevada Bar No. 8078
8950 W. Tropicana Ave., Ste. 1
Las Vegas, Nevada 89147

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8950 W. Tropicana Ave., #1
Las Vegas, NV 89147
Phone: [phone]
Fax: [phone]

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