Mariano v. City of Las Vegas et al

Filing 62

ORDER Granting 61 Stipulation for Extension of Time Re: 51 Motion for Summary Judgment. Replies due by 1/16/2021. Signed by Judge Andrew P. Gordon on 1/8/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 1 of 8

1 S. BRENT VOGEL
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Nevada Bar No. 6858
[e-mail]
JOHN M. ORR
Nevada Bar No. 14251
[e-mail]
LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
Tel.: [phone]
Fax: [phone]
Attorneys for Defendant
Correct Care Solutions, LLC

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9

UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA

11
12 ROSEN MARIANO, An individual,
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Case No. 2:18-cv-01911-APG-GWF

Plaintiff,
vs.
THE CITY OF LAS VEGAS, a political
subdivision of the State of Nevada,
CORRECTIONAL HEALTHCARE
COMPANIES, INC., A Foreign Corporation,
CORRECT CARE SOLUTIONS LLC, A
Foreign Limited Liability Company,
MICHELLE FREEMAN, Chief of Detention
Enforcement for the City of Las Vegas,
CORRECTION OFFICER DOE 1-10,
HEALTCH CARE WORKER DOES 11-20,
DOES 21-99 inclusive, ROE
CORPORATIONS 100-199, inclusive,

STIPULATION TO CONTINUE
DEFENDANT’S REPLY TO
PLAINTIFF’S OPPOSITION TO
DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT [DOC 51 and
Doc 55]

Defendants.

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The parties, by and through their respective counsel of record, hereby stipulate and

24 request that this Court extend the deadline for Defendants to file their respective Replies to
25 Plaintiff’s Oppositions to Defendant’s Motions for Summary Judgment (Doc 51 and Doc
26 55) in the above captioned case, up to and including January 16, 2021.
27

LEWIS

This request for an extension of time is not sought for any improper purpose or

28 other purpose of delay.

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

4819-2739-2982.1

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 2 of 8

1

Wherefore, the parties respectfully request that this Court extend the time for

2 Defendant to file its Reply to Plaintiff’s Oppositions to Defendant’s Motion for Summary
3 Judgment (Doc 51 and Doc 55), up to and including January 16, 2021.
4 DATED: January 7, 2021

DATED: January 7, 2021

5 THE GALLIHER LAW FIRM
6

LEWIS BRISBOIS BISGAARD & SMITH
LLP

7 /s/ Keith E. Galliher

/s/ John M. Orr
S. BRENT VOGEL
Nevada Bar No. 6858
JOHN M. ORR
Nevada Bar No. 14251
6385 S. Rainbow Boulevard, Suite 600
Las Vegas, Nevada 89118
Attorneys for Correct Care Solutions, LLC

8 KEITH E. GALLIHER, JR., ESQ.
Nevada Bar No.220
1850 E. Sahara Avenue, Suite 107
9 Las Vegas, Nevada 89104
10 Attorneys for Plaintiffs
11
12
13

DATED: January 7, 2021

14
15 /s/ John A. Curtas
16 BRADFORD R. JERBIC, ESQ.
Nevada Bar No. 1056

17 JOHN A. CURTAS
18 Nevada Bar No. 1841

495 S. Main Street, Sixth Floor
19 Las Vegas, Nevada 89101
Attorneys for City of Las Vegas
20 and Michele Freeman

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IT IS SO ORDERED
DATED: ________________, 2021
January 8

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LEWIS

BRISBOIS

BISGAARD
& SMITH LLP
ATTORNEYS AT LAW

______________________________________
UNITED STATES DISTRICT JUDGE

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Page 2 of 2

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 3 of 8
Rokni, Roya
From:
Sent:
To:
Cc:
Subject:

John A. Curtas <[e-mail]>
Thursday, January 7, 2021 3:53 PM
Orr, John; Kathleen Gallagher; Keith Galliher
Deena Mooney; Rokni, Roya; Cindy Kelly
[EXT] RE: CCS adv Mariano

Fine with me.

John A. Curtas

Deputy City Attorney
City Attorney’s Office | Civil Division
702-229-2125 (direct) | 702-528-7454 (cell)
495 South Main Street, Sixth Floor | Las Vegas, NV 89101

lasvegasnevada.gov

From: Orr, John <[e-mail]>
Sent: Thursday, January 07, 2021 3:47 PM
To: Kathleen Gallagher <[e-mail]>; Keith Galliher <[e-mail]>; John A.
Curtas <[e-mail]>
Cc: Deena Mooney <[e-mail]>; Rokni, Roya <[e-mail]>; Cindy Kelly
<[e-mail]>
Subject: RE: CCS adv Mariano

CAUTION: This email originated from an External Source. Please use caution before opening attachments,
clicking links, or responding to this email. Do not sign-in with your City of Las Vegas account credentials.
Thank you so much. Please confirm that I can affix your esignature.

John M. Orr
Attorney
[e-mail]
T: 702.693.4352 F: 702.893.3789

6385 South Rainbow Blvd., Suite 600, Las Vegas, NV 89118 | LewisBrisbois.com
Representing clients from coast to coast. View our locations nationwide.
1

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 4 of 8
This e-mail may contain or attach privileged, confidential or protected information intended only for the use of the intended recipient. If you are not the
intended recipient, any review or use of it is strictly prohibited. If you have received this e-mail in error, you are required to notify the sender, then
delete this email and any attachment from your computer and any of your electronic devices where the message is stored.

From: Kathleen Gallagher <[e-mail]>
Sent: Thursday, January 7, 2021 3:01 PM
To: Orr, John <[e-mail]>; Keith Galliher <[e-mail]>
Cc: Deena Mooney <[e-mail]>; Rokni, Roya <[e-mail]>
Subject: [EXT] Re: CCS adv Mariano
External Email

Of course. Send over the stip.

Kathleen H. Gallagher, Esq.
Of Counsel

THE GALLIHER LAW FIRM
1850 E. Sahara Avenue, Ste. 107
Las Vegas, Nevada 89104
[e-mail]
Tele: 702-735-0049
Fax: [phone]

CONFIDENTIAL. This e-mail message and the information it contains is intended only for the named
recipient(s) and may contain information that is a trade secret, proprietary, privileged, or attorney
work product. This message is intended to be privileged and confidential communications protected
from disclosure. If you are not the named recipient(s), any dissemination, distribution or copying is
strictly prohibited. If you have received this e-mail message in error, please notify the sender by email and permanently delete this message and any attachments from your workstation or network
mail system.
TAX OPINION DISCLAIMER. To comply with IRS regulations, we advise that any discussion of
Federal tax issues in this e-mail was not intended or written to be used, and cannot be used by you (i)
to avoid any penalties imposed under the Internal Revenue Code; or (ii) to promote, market or
recommend to another party any transaction or matter addressed herein.
From: Orr, John <[e-mail]>
Sent: Thursday, January 7, 2021 2:48 PM
2

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 5 of 8
To: Keith Galliher; Kathleen Gallagher
Cc: Deena Mooney; Rokni, Roya
Subject: CCS adv Mariano
Hi Keith and Kathleen
I hope you both are well and enjoyed the holidays. I’m writing to request just until Jan 16, to submit our reply to the pending MSJ.
It’s currently due on Jan 11. I hate to ask for another extension, but I’m up against a few other tight deadlines. I appreciate your
courtesy. Please let me know, and I’ll circulate a stip. Thank you, so much.
Sent from my iPhone

John M. Orr
Attorney
[e-mail]
T: 702.693.4352 F: 702.893.3789

6385 South Rainbow Blvd., Suite 600, Las Vegas, NV 89118 | LewisBrisbois.com
Representing clients from coast to coast. View our locations nationwide.
This e-mail may contain or attach privileged, confidential or protected information intended only for the use of the intended recipient. If you are not the
intended recipient, any review or use of it is strictly prohibited. If you have received this e-mail in error, you are required to notify the sender, then
delete this email and any attachment from your computer and any of your electronic devices where the message is stored.

3

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 6 of 8
Rokni, Roya
From:
Sent:
To:
Subject:

Orr, John
Thursday, January 7, 2021 4:26 PM
Rokni, Roya
FW: CCS adv Mariano

John M. Orr
Attorney
Las Vegas Rainbow
702.693.4352 or x7024352

From: Keith Galliher <[e-mail]>
Sent: Thursday, January 7, 2021 4:28 PM
To: Orr, John <[e-mail]>
Subject: [EXT] Re: CCS adv Mariano

John: You may esign for me.
From: Orr, John <[e-mail]>
Sent: Thursday, January 7, 2021 3:47 PM
To: Kathleen Gallagher; Keith Galliher; 'John A. Curtas'
Cc: Deena Mooney; Rokni, Roya; Cindy Kelly
Subject: RE: CCS adv Mariano
Thank you so much. Please confirm that I can affix your esignature.

John M. Orr
Attorney
[e-mail]
T: 702.693.4352 F: 702.893.3789
6385 South Rainbow Blvd., Suite 600, Las Vegas, NV 89118 | LewisBrisbois.com
Representing clients from coast to coast. View our locations nationwide.
This e-mail may contain or attach privileged, confidential or protected information intended only for the use of the intended recipient. If you are not the
intended recipient, any review or use of it is strictly prohibited. If you have received this e-mail in error, you are required to notify the sender, then
delete this email and any attachment from your computer and any of your electronic devices where the message is stored.

From: Kathleen Gallagher <[e-mail]>
Sent: Thursday, January 7, 2021 3:01 PM
To: Orr, John <[e-mail]>; Keith Galliher <[e-mail]>
1

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 7 of 8
Cc: Deena Mooney <[e-mail]>; Rokni, Roya <[e-mail]>
Subject: [EXT] Re: CCS adv Mariano
External Email

Of course. Send over the stip.

Kathleen H. Gallagher, Esq.
Of Counsel

THE GALLIHER LAW FIRM
1850 E. Sahara Avenue, Ste. 107
Las Vegas, Nevada 89104
[e-mail]
Tele: 702-735-0049
Fax: [phone]
CONFIDENTIAL. This e-mail message and the information it contains is intended only for the named
recipient(s) and may contain information that is a trade secret, proprietary, privileged, or attorney
work product. This message is intended to be privileged and confidential communications protected
from disclosure. If you are not the named recipient(s), any dissemination, distribution or copying is
strictly prohibited. If you have received this e-mail message in error, please notify the sender by email and permanently delete this message and any attachments from your workstation or network
mail system.
TAX OPINION DISCLAIMER. To comply with IRS regulations, we advise that any discussion of
Federal tax issues in this e-mail was not intended or written to be used, and cannot be used by you (i)
to avoid any penalties imposed under the Internal Revenue Code; or (ii) to promote, market or
recommend to another party any transaction or matter addressed herein.
From: Orr, John <[e-mail]>
Sent: Thursday, January 7, 2021 2:48 PM
To: Keith Galliher; Kathleen Gallagher
Cc: Deena Mooney; Rokni, Roya
Subject: CCS adv Mariano
Hi Keith and Kathleen
I hope you both are well and enjoyed the holidays. I’m writing to request just until Jan 16, to submit our reply to the pending MSJ.
It’s currently due on Jan 11. I hate to ask for another extension, but I’m up against a few other tight deadlines. I appreciate your
courtesy. Please let me know, and I’ll circulate a stip. Thank you, so much.
Sent from my iPhone

2

Case 2:18-cv-01911-APG-EJY Document 62 Filed 01/08/21 Page 8 of 8
John M. Orr
Attorney
[e-mail]
T: 702.693.4352 F: 702.893.3789

6385 South Rainbow Blvd., Suite 600, Las Vegas, NV 89118 | LewisBrisbois.com
Representing clients from coast to coast. View our locations nationwide.
This e-mail may contain or attach privileged, confidential or protected information intended only for the use of the intended recipient. If you are not the
intended recipient, any review or use of it is strictly prohibited. If you have received this e-mail in error, you are required to notify the sender, then
delete this email and any attachment from your computer and any of your electronic devices where the message is stored.

3