H. et al v. Clark County et al

Filing 45

ORDER granting ECF No. 44 Stipulation of Dismissal as to Defendants Ilia Hampton and Trent Hansen with Prejudice. Signed by Judge Miranda M. Du on 1/10/2018.(Copies have been distributed pursuant to the NEF - LH)

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JOHN F. BEMIS, ESQ.
Nevada Bar No. 9509
SARAH S. SILVERMAN, ESQ.
Nevada Bar No. 13624
HALL PRANGLE & SCHOONVELD, LLC
1160 North Town Center Drive, Suite 200
Las Vegas, NV 89144
[phone] – Office
[phone] – Facsimile
[e-mail]
[e-mail]
Attorneys for Defendants Eagle Quest of Nevada, Inc.,
Eagle Quest, Ivan Ray Tippetts, Leslie Tippetts,
Ilia Hampton, LCSW, QMPH, and Trent Hansen, LCSW

1160 NORTH TOWN CENTER DRIVE
SUITE 200
LAS VEGAS, NEVADA 89144
TELEPHONE: [phone]
FACSIMILE: 702-384-6025

HALL PRANGLE & SCHOONVELD, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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S.H. JOHN DOE, a minor child, by and through
his Natural Parent and Legal Guardian, A.O.
JANE DOE, an Individual; A.O. JANE DOE,
Individually;

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CASE NO. 2:17-cv-02380

Plaintiffs,

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vs.
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CLARK COUNTY, a political subdivision of
the State of Nevada; KEVIN BROWN, an
Individual; JULIANE HUGHES, an Individual;
EAGLE QUEST OF NEVADA, INC., a Nevada
Corporation; EAGLE QUEST, a Nevada
Domestic Corporation; IVAN RAY TIPPETTS,
an Individual; LESLIE TIPPETTS, an Individual;
SHERA WILLIAMS, an Individual; TOMISHA
HORN, an Individual; ILIA HAMPTON, LCSW,
QMPH, an Individual; TRENT HANSEN, LCSW,
an Individual;
Defendants.
STIPULATION AND ORDER TO DISMISS DEFENDANTS
ILIA HAMPTON AND TRENT HANSEN WITH PREJUDICE

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Page 1 of 5

IT IS HEREBY STIPULATED and agreed by and between counsel that:

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1.

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ILIA HAMPTON was an employee/agent of EAGLE QUEST and was acting in

the course and scope of her employment at all times during S.H. JOHN DOE’s foster care
placement. The parties agree that HAMPTON was acting in her individual and official capacity.

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2.

Defendant EAGLE QUEST is liable for all acts and/or omissions of ILIA

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HAMPTON, attributed to her by a finder of fact. This does not mean that Plaintiffs may not
pursue any other Defendants in this litigation on the basis of HANSEN’s acts.

1160 NORTH TOWN CENTER DRIVE
SUITE 200
LAS VEGAS, NEVADA 89144
TELEPHONE: [phone]
FACSIMILE: 702-384-6025

HALL PRANGLE & SCHOONVELD, LLC

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3.

Nothing in this stipulation will limit the evidence admitted at trial of acts and/or

omissions of ILIA HAMPTON. Nor will this stipulation, alone, limit the Plaintiffs’ ability to

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recover against any other Defendants in this case in any way.
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4.

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That Defendant ILIA HAMPTON may be dismissed, with prejudice, from the

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instant litigation in case 2:17-cv-02380, with each party to bear their own attorneys’ fees and

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costs.

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5.

TRENT HANSEN was an employee/agent of EAGLE QUEST and was acting in

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the course and scope of his employment at all times during S.H. JOHN DOE’s foster care
placement. The parties agree that HANSEN was acting in his individual and official capacity.

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6.

Defendant EAGLE QUEST is liable for all acts and/or omissions of TRENT

HANSEN, attributed to him by a finder of fact. This does not mean that Plaintiffs may not

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pursue any other Defendants in this litigation on the basis of HANSEN’s acts.
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7.

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Nothing in this stipulation will limit the evidence admitted at trial of acts and/or

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omissions of TRENT HANSEN. Nor will this stipulation, alone, limit the Plaintiffs’ ability to

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recover against any other Defendants in this case in any way.

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....

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Page 2 of 5

8.

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That Defendant TRENT HANSEN may be dismissed, with prejudice, from the

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instant litigation in case 2:17-cv-02380, with each party to bear their own attorneys’ fees and

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costs.

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IT IS SO STIPULATED.
DATED this 10th day of January, 2018.

DATED this 10th day of January, 2018.

LAGOMARSINO LAW

HALL PRANGLE & SCHOONVELD, LLC

/s/: Andre Lagomarsino, Esq.
ANDRE M. LAGOMARSINO, ESQ.
Nevada Bar No. 6711
Melanie L. Thomas, Esq.
Nevada Bar No. 12576
3005 W. Horizon Ridge Parkway, #241
Henderson, NV 89052
Attorneys for Plaintiff

/s/: John Bemis, Esq.
JOHN F. BEMIS, ESQ.
Nevada Bar No. 9509
SARAH S. SILVERMAN, ESQ.
Nevada Bar No. 13624
1160 North Town Center Drive, Suite 200
Las Vegas, NV 89144
Attorneys for Defendants Eagle Quest of
Nevada, Inc., Eagle Quest, Ivan Ray Tippetts,
Leslie Tippetts, Ilia Hampton, LCSW, QMPH,
and Trent Hansen, LCSW

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1160 NORTH TOWN CENTER DRIVE
SUITE 200
LAS VEGAS, NEVADA 89144
TELEPHONE: [phone]
FACSIMILE: 702-384-6025

HALL PRANGLE & SCHOONVELD, LLC

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DATED this 10th day of January, 2018.
OLSON, CANNON, GORMLEY,
ANGULO & STOBERSKI

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/s/: Thomas Dillard, Jr., Esq.
THOMAS D. DILLARD, JR. ESQ.
Nevada Bar No. 6270
9950 W. Cheyenne Ave.
Las Vegas, NV 89129
Attorneys for Defendants
Clark County, Kevin Brown and
Juliane Hughes
…

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…

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…

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Page 3 of 5

ORDER

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Pursuant to the foregoing stipulation of counsel for the moving parties, and good cause
appearing therefore,
1.

ILIA HAMPTON was an employee/agent of EAGLE QUEST and was acting in

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the course and scope of her employment at all times during S.H. JOHN DOE’s foster care
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placement. The parties agree that HAMPTON was acting in her individual and official capacity.

1160 NORTH TOWN CENTER DRIVE
SUITE 200
LAS VEGAS, NEVADA 89144
TELEPHONE: [phone]
FACSIMILE: 702-384-6025

2. Defendant EAGLE QUEST is liable for all acts and/or omissions of ILIA

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HALL PRANGLE & SCHOONVELD, LLC

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HAMPTON, attributed to her by a finder of fact. This does not mean that Plaintiffs may not

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pursue any other Defendants in this litigation on the basis of HANSEN’s acts.

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3. Nothing in this stipulation will limit the evidence admitted at trial of acts and/or
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omissions of ILIA HAMPTON. Nor will this stipulation, alone, limit the Plaintiffs’ ability to

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recover against any other Defendants in this case in any way.

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4. That Defendant ILIA HAMPTON may be dismissed, with prejudice, from the instant

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litigation in case 2:17-cv-02380, with each party to bear their own attorneys’ fees and costs.
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5. TRENT HANSEN was an employee/agent of EAGLE QUEST and was acting in the

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course and scope of his employment at all times during S.H. JOHN DOE’s foster care placement.

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The parties agree that HANSEN was acting in his individual and official capacity.

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6. Defendant EAGLE QUEST is liable for all acts and/or omissions of TRENT

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HANSEN, attributed to him by a finder of fact. This does not mean that Plaintiffs may not
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pursue any other Defendants in this litigation on the basis of HANSEN’s acts.

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7. Nothing in this stipulation will limit the evidence admitted at trial of acts and/or

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omissions of TRENT HANSEN. Nor will this stipulation, alone, limit the Plaintiffs’ ability to

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recover against any other Defendants in this case in any way.

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Page 4 of 5

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8. That Defendant TRENT HANSEN may be dismissed, with prejudice, from the instant
litigation in case 2:17-cv-02380, with each party to bear their own attorneys’ fees and costs.

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IT IS SO ORDERED.

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10th
January
DATED this ______ day of _________________, 2018.

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_____________________________________
UNITED STATE DISTRICT COURT JUDGE

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1160 NORTH TOWN CENTER DRIVE
SUITE 200
LAS VEGAS, NEVADA 89144
TELEPHONE: [phone]
FACSIMILE: 702-384-6025

HALL PRANGLE & SCHOONVELD, LLC

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