Armstrong v. Reynolds et al

Filing 34

ORDER Granting 33 Stipulation to Continue Date to Respond to Any Motions filed on 11/16/17 or shortly thereafter. Signed by Judge Andrew P. Gordon on 11/9/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-02528-APG-CWH Document 33 Filed 11/09/17 Page 1 of 2

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JOEL F. HANSEN, ESQ.
Nevada Bar No. 1876
COOPER LEVENSON, P.A.
1835 Village Center Circle
Las Vegas, NV 89134
[phone]: office
[phone]: facsimile
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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CLARK COUNTY, NEVADA

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HELEN ARMSTRONG

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Case No.: 2:17-cv-02528
Plaintiff,

v.

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TERRY REYNOLDS, in his individual capacity
and as Deputy Director of Nevada division of
Business and Industry; STEVE GEORGE, in his
individual capacity and as an administrator of the
Nevada Division of Industrial Relations; JESS
LANKFORD, in his individual capacity and as
Chief Administrative Officer of Nevada OSHA;
and LARA PELLEGRINI, in her individual
capacity and as Whistleblower Chief Investigator
of Nevada OSHA, DOES I through X, unknown
individuals, and ROES XI through XX, entities,
government agencies, corporations, or other
companies and/or businesses currently unknown;

STIPULATION AND ORDER TO
CONTINUE DATE TO RESPOND TO
ANY MOTIONS FILED ON
NOVEMBER 16, 2017 OR SHORTLY
THEREAFTER BY ANY OF THE
DEFENDANTS
(First Request)

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Defendants.
IT IS HEREBY STIPULATED AND AGREED between Defendants TERRY REYNOLDS,
Deputy Director of Nevada division of Business and Industry; STEVE GEORGE, Administrator of

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the Nevada Division of Industrial Relations; JESS LANKFORD, Chief Administrative Officer of

Nevada OSHA; and LARA PELLEGRINI, Whistleblower Chief Investigator of Nevada OSHA, by

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and through their counsel, Adam Paul Laxalt, Attorney General, and Deputy Attorney General

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Vivienne Rakowsky, and Plaintiff HELEN ARMSTRONG, by and through her counsel, Joel F.

Case 2:17-cv-02528-APG-CWH Document 33 Filed 11/09/17 Page 2 of 2

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Hansen of Cooper Levenson, P.A., that due to the fact that the Plaintiff’s attorney, Joel F. Hansen,

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Esq., will be having back surgery on November 16, 2017 and will be recuperating for an unknown

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period of time, that the parties stipulate that should the Defendants file any motions in response to
the Complaint of the Plaintiff, that the Plaintiff’s attorney, Joel F. Hansen, Esq., shall have until

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January 5, 2018, to respond.
Good cause exists to continue the date for the Plaintiff to respond to any motions which are

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filed in response to the Complaint due to the upcoming surgery of counsel for the Plaintiff and this is

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why the stipulation is entered into this 9th day of November, 2017.

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COOPER LEVENSON, P.A.

ADAM PAUL LAXALT, Attorney General

/s/ Joel F. Hansen
_________________________
JOEL F. HANSEN, ESQ.
Nevada Bar No. 1876
1835 Village Center Circle
Las Vegas, NV 89134
Attorneys for Plaintiff

/s/ Vivienne Rakowsky
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VIVIENNE RAKOWSKY, DAG
Nevada Bar No. 9160
555 E. Washington Ave., Ste. 3900
Las Vegas, NV 89101
Attorneys for Defendants

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ORDER
IT IS SO ORDERD.
Dated: November 9, of _______________, 2017.
DATED this ___ day2017.

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_____________________________________
UNITED STATES DISTRICT COURT JUDGE

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CLAC 4187887.1

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