Armstrong v. Reynolds et al

Filing 52

ORDER Granting 51 Stipulation to Extend Time Re: 45 Motion to Amend Complaint. Responses due by 3/16/2018. Signed by Magistrate Judge Carl W. Hoffman on 3/6/2018. (Copies have been distributed pursuant to the NEF - ADR)

1
2
3
4
5

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

6
UNITED STATES DISTRICT COURT

7

CLARK COUNTY, NEVADA

8
9

HELEN ARMSTRONG

10
11

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

v.

12
13
14
15
16
17
18
19

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
DEFENDANTS’ OPPOSITION TO
MOTION TO AMEND COMPLAINT
[#50]
(First Request)
(Oral Argument Requested)

20
21
22
23

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

24
25
26

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

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

27

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

28

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

1

Hansen of Cooper Levenson, P.A., that the parties stipulate that Plaintiff shall have until March 16,

2

2018 to respond to Defendants’ Opposition to Motion to Amend Complaint.

3
4

Parties are requesting that this motion be scheduled for oral argument.
Good cause exists to extend the date for the Plaintiff’s response to Defendants’ Opposition to

5
Motion to Amend Complaint (ECF No. 50).
6
This Stipulation is entered into this 2nd day of March, 2018.
7
8

COOPER LEVENSON, P.A.

ADAM PAUL LAXALT, Attorney General

9

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

10
11
12
13

ORDER

14
15

IT IS SO ORDERD.

16

DATED this ___ day of _______________, 2018.

17

March 6, 2018
_____________________________________
UNITED STATES DISTRICT COURT JUDGE

18
19
20
21
22
23
24
25
26
27
28
CLAC 4375152.1

2