Ward v. State of Nevada Board, ex rel, et al

Filing 30

ORDER Granting 29 Stipulation to Extend Time (First Request) Re: 1 Complaint. Don Andreas' answer due 14 days after the Court's decision at the 2/5/2018 hearing or 14 days after Plaintiff files an amended complaint if the Court so allows, whichever is later. Signed by Magistrate Judge Nancy J. Koppe on 1/30/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-03029-JAD-NJK Document 29 Filed 01/29/18 Page 1 of 2

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GARG GOLDEN LAW FIRM
ANTHONY B. GOLDEN, ESQ.
Nevada Bar No. 9563
PUNEET K. GARG, ESQ.
Nevada Bar No. 9811
3185 St. Rose Parkway, Suite 325
Henderson, Nevada 89052
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Counsel for Defendant Don Andreas

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LARA WARD, and individual,
Plaintiff,

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GARG GOLDEN
LAW FIRM
3185 St. Rose Parkway
Suite 325
Henderson, Nevada 89052
[phone]

2:17-cv-03029-JAD-NJK

STIPULATION AND [PROPOSED]
ORDER TO EXTEND THE TIME FOR
STATE OF NEVADA, ex rel. its BOARD OF
DEFENDANT DON ANDREAS TO
MEDICAL EXAMINERS, DON ANDREAS, an RESPOND TO THE COMPLAINT
individual, PAMELA CASTAGNOLA, an
individual, KIM FRIEDMAN, an individual,
(First Request)
KATI PAYTON, an individual, TODD RICH, an
individual, EDWARD COUSINEAU, an
individual, and DOES I - X,
vs.

Defendants.

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CASE NO.:

Defendant Don Andreas (“Defendant”) and Plaintiff Lara Ward (“Plaintiff”), by and
through their respective counsel of record, hereby stipulate and agree as follows:
1.

Defendant was served with the Summons and Complaint (ECF No. 1) in this case

on January 10, 2018, and Defendant’s deadline to respond to the Complaint is January 31, 2018.
2.

Prior to Defendant being served in this case, the other defendants, which were

served earlier, filed a Motion to Dismiss (ECF No. 17), a Motion to Strike (ECF No. 18), and a
Motion for a More Definite Statement (ECF No. 19). A hearing on those motions is scheduled for
February 5, 2018 (ECF No. 21).
3.

To avoid motion or pleading work by Defendant, which could be rendered moot by
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Case 2:17-cv-03029-JAD-NJK Document 29 Filed 01/29/18 Page 2 of 2

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the Court’s decision at the hearing on February 5, 2018, Defendant, Plaintiff, and their respective

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counsel are in agreement that Defendant should have until 14 days after the Court’s decision at the

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February 5, 2018 hearing or 14 days after Plaintiff files an amended complaint if the Court so

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allows, whichever is later, to respond to the Complaint or an amended complaint in this action.
4.

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This is the first request for an extension of this deadline. This stipulation is not

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made for the purposes of delay but is brought in good faith to promote efficiency avoid unnecessary

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cost.

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Dated this 29th day of January, 2018

Dated this 29th day of January, 2018

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GARG GOLDEN LAW FIRM

HKM EMPLOYMENT ATTORNEYS LLP

By /s/ Anthony B. Golden
ANTHONY B. GOLDEN, ESQ.
Nevada Bar No. 9563
3185 St. Rose Parkway, Suite 325
Henderson, Nevada 89052
[phone]
Counsel for Defendant Don Andreas

By /s/ Jenny L. Foley
JENNY L. FOLEY, Ph.D., ESQ.
Nevada Bar No. 9017
1785 East Sahara Ave., Suite 325
Las Vegas, Nevada 89104
[phone]
Counsel for Plaintiff

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ORDER
IT IS SO ORDERED

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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DATED:

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GARG GOLDEN
LAW FIRM
3185 St. Rose Parkway
Suite 325
Henderson, Nevada 89052
[phone]

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January 30, 2018