Kendrick v. Clark County

Filing 27

ORDER granting 26 Stipulation; Re: 21 Motion to Dismiss. Responses due by 9/19/2018. Signed by Judge Jennifer A. Dorsey on 9/10/2018. (Copies have been distributed pursuant to the NEF - JM)

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ATTORNEYS AT LAW
7435 W. AZURE DR., SUITE 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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JAMES P. KEMP, ESQ.
Nevada Bar No.: 6375
VICTORIA L. NEAL, ESQ.
Nevada Bar No.: 13382
KEMP & KEMP
7435 W. Azure Drive, Ste 110
Las Vegas, NV 89130
702-258-1183 ph./702-258-6983 fax
[e-mail]
[e-mail]
Attorneys for Plaintiff
Johnny L. Kendrick, Jr.
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
***
)
)
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Plaintiff,
)
v.
)
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CLARK COUNTY, a political subdivision of )
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the State of Nevada; JOHN MARTIN in his
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official and/or individual capacities; PATRICK )
SCHREIBER in his official and/or individual )
capacities; CAROLYN BANKS, in her official )
)
and/or individual capacities; and, SANDY
)
JEANTETE, in her official and/or individual
)
capacities,
)
Defendants. )
JOHNNY L. KENDRICK, JR.,

Case No.: 2:18-cv-00781-JAD-GWF

STIPULATION AND ORDER TO
EXTEND PLAINTIFF’S DEADLINE
TO RESPOND TO DEFENDANT’S
MOTION TO DISMISS (ECF NO. 21)
(First Request)

Pursuant to Local Rule (“LR”) IA 6-1, LR IA 6-2, and LR 7-1, Plaintiff, Johnny L.
Kendrick, Jr. (herein “Plaintiff”), by and through his undersigned counsel, James P. Kemp, Esq.,

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and Victoria L. Neal, Esq., of the law firm of Kemp & Kemp, and Defendants, Clark County, et

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al., by and through its undersigned counsel, Steven B. Wolfson, District Attorney, and Scott R.

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Davis, Deputy District Attorney, hereby agree to extend the time for Plaintiff to file a response

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to Defendants’ Motion to Dismiss (ECF No. 21), up to and including September 19, 2018. The

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present deadline is September 12, 2018. Hearing on this matter is set for October 15, 2018. This

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is the parties’ first request for an extension of time to respond to Defendants’ Motion to Dismiss.

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Plaintiff’s counsel would like the additional time to thoroughly review and conduct the

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required research of Defendants’ position and case law in order to appropriately and completely

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respond to their arguments. Both of Plaintiff’s counsel have been extraordinarily busy including,

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but not limited to, attending a two-day DIR conference, drafting an opening brief to the Ninth

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Circuit Court of Appeals, drafting a writ of certiorari to the United States Supreme Court,

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drafting an opening brief to the Supreme Court of Nevada, drafting complaints for which the

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Right To Sue (EEOC) deadlines were to expire, responding to discovery requests, drafting initial

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disclosures, drafting additional motions or replies including a motion to enforce, client meetings

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ATTORNEYS AT LAW
7435 W. AZURE DR., SUITE 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

for deposition and ENE prep, court appearances, and the intervening Labor Day holiday.
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Therefore, the parties agree that an extension of time is appropriate.

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IT IS SO STIPULATED:

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Dated: September 10, 2018.

Dated: September 10, 2018.

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Respectfully submitted,

Respectfully submitted,

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/s/ Victoria L. Neal
JAMES P. KEMP, ESQ.
8 VICTORIA L. NEAL, ESQ.
KEMP & KEMP
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10 Attorneys for Plaintiff
JOHNNY KENDRICK, JR.
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/s/ Scott R. Davis
STEVEN B. WOLFSON
DISTRICT ATTORNEY
SCOTT R. DAVIS
DEPUTY DISTRICT ATTORNEY
Attorneys for Defendant
CLARK COUNTY, JOHN MARTIN, PATRICK
SCHREIBER, SANDY JEANTETE and
CAROLYN BANKS

ATTORNEYS AT LAW
7435 W. AZURE DR., SUITE 110
LAS VEGAS, NEVADA 89130
Tel. [phone] ♦ Fax [phone]

KEMP & KEMP

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IT IS SO ORDERED.
Dated: _____________________, 2018.

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_______________________________________
UNITED STATES DISTRICT COURT JUDGE
JENNIFER A. DORSEY
Dated: September 10, 2018.

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