Tripp v. Clark County et al

Filing 250

ORDER Granting 249 Stipulation for extension of time to respond to 244 Motion for Summary Judgment. Responses due by 12/2/2022. Signed by Judge James C. Mahan on 11/18/2022. (Copies have been distributed pursuant to the NEF - LOE)

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
7
UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9

HATFIELD & ASSOCIATES, LTD.

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

10

JUSTIN L. TRIPP,

11
12
13

Plaintiff,
vs.
CLARK COUNTY, et al

14

Defendants.

CASE NO: 2:17-cv-01964-JCM-BNW
STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF TO
RESPOND TO NAPHCARE
DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT (ECF #244)
(Third Request)

15
COMES NOW, Plaintiff Justin Tripp (“Plaintiff”), by and through his counsel, the law
16
17

firm of Hatfield & Associates., Ltd., appearing pro bono publico, and Defendant NaphCare, Inc.,

18 Defendant Harry Duran, M.D., Defendant Eric Lopez, P.A., Defendant Rachel Scheiblich,
19 Defendant Kendra Meyer, and Defendant Raymond Mondora, (hereinafter “NaphCare
20

Defendants”), by and through their counsel, the law firm of Medical Defense Law Group, and

21
hereby stipulate and agree to extend the time for Plaintiff to Respond to the NaphCare
22
23

Defendants’ Motion for Summary Judgment [ECF #244], due on November 18, 2022 to

24 December 2, 2022.
25
26

This request is submitted pursuant to LR IA 6-1, 6-2 and 7-1 and is the parties’ third
request for an extension of time for Plaintiff to respond to Defendants’ Motion for Summary

27
Judgment.
28

1

Good cause exists for this extension. Plaintiff is incarcerated in F.C.I. Herlong, in Herlong,

2 California and Plaintiff’s Counsel has had difficulty communicating with him. Plaintiff's counsel is
3 requesting an extension of time up to and including December 2, 2022, as Plaintiff requested
4 authority from his incarcerated client to make an offer to resolve this case to Defendants and
5
received that authority and made the offer to Defendants’ counsel on October 19, 2022.
6
Defendants responded to the offer on October 25, 2022 with a counteroffer that Plaintiff’s
7
8 counsel needs to convey to Plaintiff.

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

HATFIELD & ASSOCIATES, LTD.

9

Plaintiff’s counsel continues to have difficulty communicating with Plaintiff as F.C.I.

10 Herlong is experiencing a Level 3 Lockdown due to Covid. Inmates are not able to take phone
11
calls or have access to a computer during the lockdown. If Defendants’ offer is accepted, the
12
case would then resolve in the entirety whereby the motion may be made moot, but time is
13
14 needed to convey the counteroffer to Plaintiff.
15 ///
16 ///
17
///
18
///
19
20 ///
21 ///
22 ///
23
///
24
///
25
26 ///
27 ///
28 ///

-2-

1

Defendants have courteously granted this extension of time for Plaintiff to file his

2 Response. Accordingly, Plaintiff shall have up to and including December 2, 2022, to respond

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

HATFIELD & ASSOCIATES, LTD.

3 to NaphCare Defendants’ Motion for Summary Judgment [ECF #244].
4 DATED this 17th day of November, 2022
5
HATFIELD & ASSOCIATES, LTD.
6
By:
/s/ Trevor J. Hatfield
7
TREVOR J. HATFIELD, ESQ. (SBN 7373)
703 S. Eighth Street
8
Las Vegas, Nevada 89101
Tel.: [phone]
9
Email: [e-mail]
Attorney for Plaintiff In Conjunction with
10
Legal Aid Center of Southern Nevada Pro
Bono Project.
11
12
13

DATED this 17th day of November, 2022
MEDICAL DEFENSE LAW GROUP
By:_____Paul A. Cardinale__________
PAUL A. CARDINALE, ESQ. (SBN 8394)
3800 Watt Avenue, Suite 245
Sacramento, California 95821
Tel.: [phone]
Email: [e-mail]
Southern Nevada Office:
2965 South Jones Blvd., Suite E1
Las Vegas, NV 89146
Tel.: [phone]
Attorneys for NAPHCARE Defendants

14
15
16
17
18
19

ORDER

20 IT IS SO ORDERED:
21

UNITED STATES DISTRICT COURT JUDGE

22

Dated:

November 18, 2022

23
24
25
26
27
28

-3-