Herndon v. Henderson Police Department et al

Filing 69

ORDER granting 67 Stipulation to Extend Briefing Deadlines Re: 55 Motion for Summary Judgment. Responses due by 12/9/2020. Replies due by 1/18/2021. Signed by Judge Gloria M. Navarro on 12/1/2020. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:19-cv-00018-GMN-NJK Document 69 Filed 12/01/20 Page 1 of 3

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Marjorie L. Hauf, Esq.
2 Nevada Bar No.: 8111
Matthew G. Pfau, Esq.
3 Nevada Bar No.: 11439
Cara Xidis, Esq.
4 Nevada Bar No.: 11743
H&P LAW
5 8950 W Tropicana Ave., #1
Las Vegas, NV 89147
6 702 598 4529 TEL
702 598 3626 FAX
7 [e-mail]
[e-mail]
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Attorneys for Plaintiff,
9 James M. Herndon
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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James M. Herndon,

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CASE NO.: 2:19-cv-00018-GMN-NJK

Plaintiff,
vs.
City of Henderson, a political Second Stipulation and Proposed
to
Extend
Briefing
subdivision of The State of Nevada; Sgt. Order
M. Gillis, individually and in his official Deadlines (ECF # 55)
capacity as a police officer; Officer L.
Good, individually and in his official
capacity as a police officer; Officer A.
Nelson, individually and in his official
capacity as a police officer; Officer D.
Nerbonne, individually and in his official
capacity as a police officer; Officer D.
Russo, individually and in his official
capacity as a police officer; Officer E.
Vega, individually and in his official
capacity as a police officer; Doe Officers
I through X, inclusive and Roe Entities I
through X, inclusive
Defendants.

Case 2:19-cv-00018-GMN-NJK Document 69 Filed 12/01/20 Page 2 of 3

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Plaintiff, James Herndon, through his counsel of record, Marjorie L. Hauf, Esq. and

2 Matthew G. Pfau, Esq.. of H & P LAW, and Defendants, City of Henderson, Sgt. M.
3 Gillis, Officer L. Good, Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and
4 Officer E. Vega through their counsel of record, Nicholas G. Vaskov, Esq. and Nancy
5 D. Savage, Esq. of CITY ATTORNEY’S OFFICE, do hereby stipulate and agree to
6 Extend the due dates of Plaintiff’s Opposition to Defendants, Sgt. M. Gillis, Officer L.
7 Good, Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and Officer E. Vega’s
8 Motion for Summary Judgment and Defendant’s Reply in Support to Defendants, Sgt.
9 M. Gillis, Officer L. Good, Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo,
10 and Officer E. Vega’s Motion for Summary Judgment.
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Currently, Plaintiff’s Opposition is due December 2, 2020. Plaintiff and Defendant

12 agree to Extend the Deadline for Plaintiff to file his Opposition to December 9, 2020.
13 and for Defendant to file their Reply in Support to January 18, 2021. The extensions
14 are being requested in good faith and not for the purpose of delay. The extensions
15 are being requested as the issues to be briefed are extensive and complicated.
16 Plaintiff’s co-cousenl, Micah Echols, Esq. of CLAGGETT & SYKES, had a recent
17 COVID-19 outbreak in his office, and as such, they have been closed for in person
18 operations. This setback unfortunately delayed Plaintiff’s efforts to oppose this
19 motion. The parties also anticipate the end of the year holidays will further
20 complicate the briefing schedule, nescessitating a further extension for Defendants
21 to file their Reply.
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Stipulation
It is hereby STIPULATED between James Herndon, through his counsel of record,

25 Marjorie L. Hauf, Esq. and Matthew G. Pfau, Esq.. of H & P LAW, and Defendants,
26 City of Henderson, Sgt. M. Gillis, Officer L. Good, Officer A. Nelson, Officer D.
27 Nerbonne, Officer D. Russo, and Officer E. Vega through their counsel of record,
28 Nicholas G. Vaskov, Esq. and Nancy D. Savage, Esq. of CITY AT TORNEY’S OFFICE,
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S E CO N D S T IP U LAT IO N A N D O RD E R TO EX TE N D C E RTA IN D EA D LIN ES E C F # 5 5

Case 2:19-cv-00018-GMN-NJK Document 69 Filed 12/01/20 Page 3 of 3

1 to Extend Breifing Deadlines Related to Defendants, Sgt. M. Gillis, Officer L. Good,
2 Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and Officer E. Vega’s Motion
3 for Summary Judgment and Defendant’s Reply in Support to Defendants, Sgt. M.
4 Gillis, Officer L. Good, Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and
5 Officer E. Vega’s Motion for Summary Judgment, ECF # 55.
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IT IS FURTHER STIPULATED that Plaintiff’s Opposition to Defendant, Sgt. M.

7 Gillis, Officer L. Good, Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and
8 Officer E. Vega’s Motion for Summary Judgment must be filed by December 9, 2020.
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IT IS FURTHER STIPULATED that Defendants, Sgt. M. Gillis, Officer L. Good,

10 Officer A. Nelson, Officer D. Nerbonne, Officer D. Russo, and Officer E. Vega’s Reply
11 in Support of Motion for Summary Judgment must be filed by January 18, 2021.
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DATED this 1st day of December 2020.
Respectfully submitted by:
H & P LAW
/s/ Marjorie Hauf, Esq.
Marjorie L. Hauf, Esq.
Nevada Bar No.: 8111
Matthew G. Pfau, Esq.
Nevada Bar No.: 11439

/s/ Nancy Savage, Esq.
Nicholas G. Vaskov, Esq.
Nevada Bar No.: 8298
Nancy D. Savage, Esq.
Nevada Bar No.: 392

Attorneys for Plaintiff,
James M. Herndon

Attorneys for Defendants,
City of Henderson, Sgt. S. Gillis, and
Officers L. Good, A. Nelson, D.
Nerbonne, D. Russo, and E. Vega

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Approved as to form and content:
CITY AT TORNEY’S OFFICE

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IT IS SO ORDERED.

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Dated this ____ day of December, 2020

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___________________________
Gloria M. Navarro, District Judge
UNITED STATES DISTRICT COURT

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S E CO N D S T IP U LAT IO N A N D O RD E R TO EX TE N D C E RTA IN D EA D LIN ES E C F # 5 5