Tripp v. Clark County et al

Filing 216

ORDER granting 215 Stipulation Re: 197 , 198 , 199 , 200 , 201 Motions for Summary Judgment. Responses due by 12/13/2021. Signed by Judge James C. Mahan on 10/12/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:17-cv-01964-JCM-BNW Document 215 Filed 10/08/21 Page 1 of 4

TREVOR J. HATFIELD, ESQ
1 Nevada Bar No. 7373
2 HATFIELD & ASSOCIATES, LTD.
703 S. Eighth Street
3 Las Vegas, Nevada 89101
Telephone: [phone]
4 Facsimile: [phone]
5 Email: [e-mail]
Attorney for Plaintiff In conjunction with Legal Aid
6 Center of Southern Nevada Pro Bono Project
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HATFIELD & ASSOCIATES, LTD.

703 S.8th Street * Las Vegas, Nevada 89101
Telephone [phone]

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JUSTIN L. TRIPP,

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Plaintiff,

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vs.
CLARK COUNTY, et al

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Defendants.

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STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANTS’
MOTIONS FOR SUMMARY
JUDGMENT
(Third Request)

COMES NOW, Plaintiff Justin Tripp (“Plaintiff”), by and through his counsel, the law

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CASE NO: 2:17-cv-01964-JCM-BNW

firm of Hatfield & Associates., Ltd., appearing pro bono publico, and Defendant Cesar Esparza,

18 Defendant Las Vegas Metropolitan Police Department, Defendants Michael Rose and Jacqulyn
19 Schumaker and Defendants LVMPD Sergeants’ (hereinafter “LVMPD Defendants”) by and
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through their counsel, the law firm of Kaempfer Crowell, and Defendant NaphCare, Inc.,
Defendant Harry Duran, M.D., Defendant Eric Lopez, P.A., Defendant Rachel Scheiblich,
Defendant Kendra Meyer, and Defendant Raymond Mondora, (hereinafter “NaphCare

24 Defendants”), by and through their counsel, the law firm of Lauria Tokunaga Gates & Linn,
25 LLP, hereby stipulate and agree to extend the time for Plaintiff to Respond to the following
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Defendants’ Motions for Summary Judgment, due on October 14, 2021, to December 13, 2021:
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Case 2:17-cv-01964-JCM-BNW Document 215 Filed 10/08/21 Page 2 of 4

1.

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2. Defendant Las Vegas Metropolitan Police Department’s Motion for Summary Judgment

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[ECF #199];

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3. Defendants Michael Rose’s and Jacqulyn Schumaker’s Motion for Summary Judgment

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[ECF #200];

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4. Defendants’ LVMPD Sergeants’ Motion for Summary Judgment [ECF #201].

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5. NaphCare Defendants’ Motion for Summary Judgment [ECF #197].

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703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

Defendant Cesar Esparza’s Motion for Summary Judgment [ECF #198];

This request is submitted pursuant to LR IA 6-1, 6-2 and 7-1 and is the parties’ third

10 request for an extension of time for Plaintiff to respond to Defendants’ Motions for Summary
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Judgment.
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Good cause exists for this extension. Plaintiff's counsel is requesting a sixty (60) day
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14 extension of time up to and including December 13, 2021, to respond to all parties' Motions for
15 Summary Judgment as Plaintiff is in prison, communication must be scheduled, and the volume
16 of the motions. Plaintiff informed his counsel in July 2021 that he was being transferred to
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another Federal Prison but did not know when he would arrive and where he would be residing
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at that time. Plaintiff has been transported to several Federal Prison’s since July 2021, each time
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20 having to deal with a twenty-one (21) day quarantine, but as of today, we have not been able to
21 ascertain if he has arrived at his final destination.
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In addition, Plaintiff was not permitted to take his legal documents with him in transit.
Therefore, Plaintiff’s counsel shall have to forward all of the legal documents to his new prison
location once known. Defendants have courteously granted this extension of time for Plaintiff to

26 file his Responses. Accordingly, Plaintiff shall have up to and including December 13, 2021, to
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Case 2:17-cv-01964-JCM-BNW Document 215 Filed 10/08/21 Page 3 of 4

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respond to Defendants’ Motions for Summary Judgment [ECF #198], [ECF #199], [ECF #200],

2 [ECF #201] and [ECF #197].

703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

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4 DATED this 8th day of October, 2021
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HATFIELD & ASSOCIATES
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/s/ Trevor J. Hatfield
7 By:
TREVOR J. HATFIELD, ESQ. (SBN 7373)
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703 S. Eighth Street
Las Vegas, Nevada 89101
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Tel: [phone]
Email: [e-mail]
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Attorney for Plaintiff In Conjunction with
Legal Aid Center of Southern Nevada Pro
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Bono Project.
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DATED this 8th day of October, 2021
KAEMPFER CROWELL
/s/ Lyssa S. Anderson
By:
LYSSA S. ANDERSON, ESQ. (SBN 5781)
RYAN W. DANIELS, ESQ. (SBN 13094)
1980 Festival Plaza Drive, Ste. 650
Las Vegas, Nevada 89135
Tel: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendants Cesar Esparza,
Michael Rose, Jacqulyn Schumaker, LVMPD
Sergeants’.

703 8th Street * Las Vegas, Nevada 89101
Telephone [phone]

HATFIELD & ASSOCIATES, LTD.

Case 2:17-cv-01964-JCM-BNW Document 215 Filed 10/08/21 Page 4 of 4

1 DATED this 8th day of October, 2021.
2
LAURIA TOKUNAGA GATES & LINN, LLP
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/s/ Paul A. Cardinale
4 By:
_________________
PAUL A. CARDINALE, ESQ. (SBN 8394)
5
1755 Creekside Oaks Drive, Suite 240
6 Sacramento, CA 95833
Tel.: [phone]
7 Email: [e-mail]
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Southern Nevada Office:
9 601 South Seventh Street
Las Vegas, NV 89101
10 Tel.: [phone]
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Attorneys for NAPHCARE, INC., an Alabama Corporation; HARRY DURAN, M.D., in his
12 individual capacity; ERIC LOPEZ, P.A., in his individual capacity; RACHEL SCHEIBLICH
(formerly known as “RUDD”) in her individual capacity; KENDRA MEYER (formerly known as
13 SCHULTZ”) in her individual capacity, and RAYMOND MONDORA
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ORDER

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IT IS SO ORDERED:
UNITED STATES DISTRICT COURT JUDGE
Dated:

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October 12, 2021