Wolf et al v. Clark County Department of Family Services et al

Filing 87

ORDER Granting 84 Unopposed Motion for Extension of Time Re: 81 Motion for Summary Judgment. Responses due by 6/29/2018. Replies due by 7/13/2018. Signed by Judge James C. Mahan on 6/18/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02084-JCM-NJK Document 86 Filed 06/18/18 Page 1 of 5

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ALLEN M. RESSLER, ESQ. (WSBA #5330)
LAW OFFICES OF RESSLER & TESH
Penthouse Suite
821 Second Avenue
Seattle, Washington, 98104
Attorneys for Plaintiffs110
Tel: [phone]

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JUSTIN L. WILSON, ESQ.
JONES WILSON LLP
Nevada Bar No. 7560
1522 W. Warm Springs Road
Henderson, Nevada 89014
Tel: [phone]
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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BRUCE WOLF, as Litigation Guardian No. 2:17-cv-02084-JCM-NJK
Ad Litem for C.A.R., D.O.B.:
1/19/2002, C.J.R., D.O.B.: 1/17/2005 STIPULATED MOTION TO
and G.Y.R., D.O.B: 10/7/2006
EXTEND THE DEADLINES FOR
PLAINTIFFS’ RESPONSE AND
DEFENDANTS’ REPLY TO
Plaintiffs,
DEFENDANTS CLARK COUNTY,
SHAY RIGGS-HORN, ASHLEY
v.
DURROUGH AND TROY
CLARK COUNTY, THE STATE OF ARMSTRONG’S MOTION FOR
NEVADA
DEPARTMENT
OF SUMMARY JUDGMENT AS TO
HEALTH AND HUMAN SERVICES, PLAINTIFF C.A.R.’S CLAIMS
NEVADA DIVISION OF CHILDREN
AND FAMILY SERVICES AND
JOHN AND JANE DOE 1-10.
Defendants.
STIPULATED MOTION TO EXTEND THE
DEADLINES FOR RESPONSE AND REPLY
TO DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT AS TO PLAINTIFF C.A.R.’S CLAIMS
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Law Offices of Ressler & Tesh
Penthouse Suite
821 Second Avenue
Seattle, WA 98104
[phone]

Case 2:17-cv-02084-JCM-NJK Document 86 Filed 06/18/18 Page 2 of 5

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COMES NOW the parties by and through their counsel, the Plaintiffs,

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through their attorneys Allen M. Ressler of Ressler & Tesh, PLLC and Justin

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Wilson of Jones Wilson, LLP, and the Defendants, through their attorney Felicia

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Galati of Olson, Cannon, Gormley, Anguelo & Stoberski, stipulate that the
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Plaintiffs’ response to Defendants Clark County, Shay Riggs-Horn, Ashley

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Durrough and Troy Armstrong’s Motion for Summary Judgment as to Plaintiff

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C.A.R.’s Claims (Docket No. 81) be extended from June 19, 2018 to June 29,

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2018. Defendants filed their Motion for Summary Judgment on May 29, 2018.

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The parties also stipulate that Defendants’ reply be extended the same

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length as Plaintiffs’ response such that Defendants’ reply will be due on July 13,
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2018. The schedule of Plaintiffs’ counsel is such that they will be unable to meet

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the court’s response deadline of June 19, 2018. In addition, counsel for

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Defendants will be out of the office for a week in July. The parties believe that it

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would be appropriate to extend the response and reply deadlines an additional ten

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calendar days.

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This is the first stipulation for extension of time to respond to Defendants’
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Motion for Summary Judgment.

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STIPULATED MOTION TO EXTEND THE
DEADLINES FOR RESPONSE AND REPLY
TO DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT AS TO PLAINTIFF C.A.R.’S CLAIMS
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Law Offices of Ressler & Tesh
Penthouse Suite
821 Second Avenue
Seattle, WA 98104
[phone]

Case 2:17-cv-02084-JCM-NJK Document 86 Filed 06/18/18 Page 3 of 5

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DATED this 18th day of June, 2018.
RESSLER & TESH, PLLC

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Allen M. Ressler, WSBA No. 5330
821 – 2nd Avenue, Suite 2200
Seattle, WA 98104
Tel: [phone]
Fax: [phone]
Counsel for Plaintiffs
[e-mail]

JONES WILSON, LLP
/s/ Justin L. Wilson
Justin L. Wilson, Esq.
Nevada Bar No. 7560
1522 W. Warm Springs Road
Henderson, NV 89014
Co-Counsel for Plaintiffs
Tel: [phone]
[e-mail]

OLSON, CANNON, GORMLEY,
ANGULO & STOBERSKI
/s/ Felicia Galati
Felicia Galati, Esq.
Nevada Bar No. 9660
9950 West Cheyanne Avenue
Las Vegas, NV 89129
Tel: [phone]
[e-mail]

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STIPULATED MOTION TO EXTEND THE
DEADLINES FOR RESPONSE AND REPLY
TO DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT AS TO PLAINTIFF C.A.R.’S CLAIMS
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Law Offices of Ressler & Tesh
Penthouse Suite
821 Second Avenue
Seattle, WA 98104
[phone]

Case 2:17-cv-02084-JCM-NJK Document 86 Filed 06/18/18 Page 4 of 5

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ORDER
IT IS SO ORDERED June____ day of June, 2018.
this 18, 2018.

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____________________________________
UNITED STATES MAGISTRAGE
UNITEDSTATES DISTRICT JUDGE JUDGE

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Submitted by:
RESSLER & TESH, PLLC

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Allen M. Ressler, WSBA No. 5330
821 – 2nd Avenue, Suite 2200
Seattle, WA 98104
Counsel for Plaintiffs

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STIPULATED MOTION TO EXTEND THE
DEADLINES FOR RESPONSE AND REPLY
TO DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT AS TO PLAINTIFF C.A.R.’S CLAIMS
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Law Offices of Ressler & Tesh
Penthouse Suite
821 Second Avenue
Seattle, WA 98104
[phone]

Case 2:17-cv-02084-JCM-NJK Document 86 Filed 06/18/18 Page 5 of 5

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CERTIFICATE OF SERVICE
I hereby certify that I served a copy of the foregoing to the following
counsel of record via the method indicated:

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Felicia Galati, Esq., Nevada Bar No. 7341 [ ] Via Facsimile
OLSON, CANNON, GORMLEY,
[ ] Via USPS Mail
ANGULO & STOBERSKI
[X] Via Electronic Mail/E-Service
Attorney for Defendant Clark County
9950 West Cheyenne Avenue
Las Vegas, NV 89129
Tel: [phone]
[e-mail]
Justin L. Wilson, Esq.
Nevada Bar No. 7560
JONES WILSON, LLP
1522 W. Warm Springs Road
Henderson, NV 89014
Co-Counsel for Plaintiffs
Tel: [phone]
[e-mail]

[ ] Via Facsimile
[ ] Via USPS Mail
[X] Via Electronic Mail/
E-Service

DATED this 18th day of June, 2018 at Seattle, Washington
RESSLER & TESH, PLLC

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Khanh T. Tran, Paralegal

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STIPULATED MOTION TO EXTEND THE
DEADLINES FOR RESPONSE AND REPLY
TO DEFENDANTS’ MOTION FOR SUMMARY
JUDGMENT AS TO PLAINTIFF C.A.R.’S CLAIMS
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Law Offices of Ressler & Tesh
Penthouse Suite
821 Second Avenue
Seattle, WA 98104
[phone]