Farah v. Las Vegas Metro Police Department et al

Filing 18

ORDER granting 15 VERIFIED PETITION FOR DAVID OWENS and 16 VERIFIED PETITION FOR SARAH GRADY. Signed by Judge Richard F. Boulware, II on 6/19/2020. (Attachments: # 1 Verified Petition for Sarah Grady)(Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 1 of 14

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LUKE A. BUSBY, ESQ
Nevada Bar No. 10319
LUKE ANDREW BUSBY, LTD.
316 California Ave # 82
Reno, Nevada 89509
O: 775.453.0112
[e-mail]
Designated Resident Nevada Counsel for Plaintiff
Sarah Grady*
David B. Owens*
Loevy & Loevy
Loevy & Loevy
311 N. Aberdeen St., 3rd Fl.
100 S. King St., St. 100
Chicago, IL 60607
Seattle, WA 98104
O: 312.243.5900
O: 312-243-5900
[e-mail]
[e-mail]
*Verified petitions for permission to practice forthcoming
Counsel for Plaintiff Craig Farah, Personal Representative
of the Estate of Nicholas Farah

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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CRAIG FARAH, Personal
Representative of the ESTATE OF
NICHOLAS FARAH,

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Plaintiff,

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vs.

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No. 2:20-cv-00604

LAS VEGAS METROPOLITAN
POLICE DEPARTMENT; RICHARD
NEWMAN; SAMUEL MENDOZA;
AARON MOSELY; JEREMY
STEWART; CHRISTY SNAPP;
GABRIEL VILLANUEVA; KIM SOFFE;
and COLLIN PETRIELIUS,

PLAINTIFF’S UNOPPOSED
MOTION FOR LEAVE TO FILE
INSTANTER VERIFIED PETITION
FOR DAVID OWENS AND MOTION
FOR EXTENSION OF TIME TO
FILE VERIFIED PETITION FOR
SARAH GRADY

Defendants.

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Now comes Plaintiff, Craig Farah, as Personal Representative of the Estate

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of Nicholas Farah, by and through his undersigned counsel, and respectfully

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requests that this Court permit Plaintiff’s attorney, David Owens, leave to file his

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verified petition for permission to practice in this case instanter. Plaintiff further
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Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 2 of 14

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requests an extension of time to June 11 to file Sarah Grady’s verified petition for

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permission to practice in this case. In support of his requests, Plaintiff states as

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follows:

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1.

Plaintiff has filed a 42 U.S.C. § 1983 lawsuit against the Las Vegas

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Metropolitan Police Department and others over the death of his son, Nicholas

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Farah, at the Clark County Detention Center (CCDC) on March 31, 2019. Dkt. 1.

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2.

Plaintiff is represented in this lawsuit by David Owens and Sarah

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Grady at Loevy & Loevy, a civil rights law firm headquartered in Chicago. They are

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not licensed to practice law in the State of Nevada, but are working with the

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undersigned as Designated Resident Nevada Counsel for Plaintiff.
3.

This Court previously ordered counsel to file verified petitions by May

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16, 2020. Dkt. 3. Unfortunately, because of difficulties due to the COVID-19

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pandemic, and uncertainty regarding counsel’s ability to obtain the required

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notarization of the verified petitions while under stay-at-home orders, counsel was

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unable to file their petitions by the May 16 deadline.

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4.

Counsel has since resolved these issues, and been able to begin

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completing the verified petitions. Accordingly, Plaintiff has attached to this motion

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the required verified petition for permission to practice in this case for David

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Owens. Ex. A.

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5.

Unfortunately, Sarah Grady’s verified petition is not yet complete, as

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she is still waiting to receive a certificate of good standing from the State of New

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York, one of the two states where she is licensed to practice law. Accordingly,

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Plaintiff respectfully requests a brief extension of time, up to and including June 11,

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to provide Ms. Grady’s verified petition.

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6.

Counsel for Plaintiff has conferred with counsel for the Defendants

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(excepting Defendant Collin Petrielius who has not yet been served). Counsel for

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Defendants report that they do not oppose Plaintiff’s request.

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Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 3 of 14

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WHEREFORE, Plaintiff respectfully requests that this Court permit

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Plaintiff’s attorney, David Owens, leave to file his verified petition for permission to

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practice in this case instanter, and to permit Plaintiff’s attorney, Sarah Grady, a

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brief extension of time to June 11 to file her verified petition for permission to

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practice.

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Dated:

May 28, 2020

Respectfully submitted,

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CRAIG FARAH

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By: /s/ Luke A Busby
Designated Resident Nevada Counsel
for Plaintiff

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LUKE A. BUSBY, ESQ
Nevada Bar No. 10319
LUKE ANDREW BUSBY, LTD.
316 California Ave # 82
Reno, Nevada 89509
O: 775.453.0112
[e-mail]
Designated Resident Nevada Counsel for Plaintiff
Sarah Grady*
David B. Owens*
Loevy & Loevy
Loevy & Loevy
311 N. Aberdeen St., 3rd Fl.
100 S. King St., St. 100
Chicago, IL 60607
Seattle, WA 98104
O: 312.243.5900
O: 312-243-5900
[e-mail]
[e-mail]
*Verified petitions for permission to practice forthcoming
Counsel for Plaintiff Craig Farah, Personal Representative
of the Estate of Nicholas Farah

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CERTIFICATE OF SERVICE

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I, Luke A. Busby, an attorney, hereby certify that on May 27, 2020, I filed
the foregoing via CM/ECF, which effected service on all counsel of record. I further
certify that I will ensure that Defendant Collin Petrielius receives a copy of the
foregoing at the time that he is served with notice of this lawsuit pursuant to Rule 4
of the Federal Rules of Civil Procedure.

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/s/ Luke A Busby
Designated Resident Nevada Counsel
for Plaintiff

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Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 4 of 14

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LUKE A. BUSBY, ESQ
Nevada Bar No. 10319
LUKE ANDREW BUSBY, LTD.
316 California Ave # 82
Reno, Nevada 89509
O: 775.453.0112
[e-mail]
Designated Resident Nevada Counsel for Plaintiff
Sarah Grady*
David B. Owens*
Loevy & Loevy
Loevy & Loevy
311 N. Aberdeen St., 3rd Fl.
100 S. King St., St. 100
Chicago, IL 60607
Seattle, WA 98104
O: 312.243.5900
O: 312-243-5900
[e-mail]
[e-mail]
*Verified petitions for permission to practice forthcoming
Counsel for Plaintiff Craig Farah, Personal Representative
of the Estate of Nicholas Farah

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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CRAIG FARAH, Personal
Representative of the ESTATE OF
NICHOLAS FARAH,

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Plaintiff,

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vs.

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No. 2:20-cv-00604

LAS VEGAS METROPOLITAN
POLICE DEPARTMENT; RICHARD
NEWMAN; SAMUEL MENDOZA;
AARON MOSELY; JEREMY
STEWART; CHRISTY SNAPP;
GABRIEL VILLANUEVA; KIM SOFFE;
and COLLIN PETRIELIUS,

PLAINTIFF’S LIST OF EXHIBITS
FOR UNOPPOSED MOTION FOR
LEAVE TO FILE INSTANTER
VERIFIED PETITION FOR DAVID
OWENS AND MOTION FOR
EXTENSION OF TIME TO
FILE VERIFIED PETITION FOR
SARAH GRADY

Defendants.

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No.

Description

A

David Owens Verified Petition

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1

Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 5 of 14

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Dated:

May 28, 2020

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Respectfully submitted,

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CRAIG FARAH

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By: /s/ Luke A Busby
Designated Resident Nevada Counsel
for Plaintiff

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LUKE A. BUSBY, ESQ
Nevada Bar No. 10319
LUKE ANDREW BUSBY, LTD.
316 California Ave # 82
Reno, Nevada 89509
O: 775.453.0112
[e-mail]
Designated Resident Nevada Counsel for Plaintiff
Sarah Grady*
David B. Owens*
Loevy & Loevy
Loevy & Loevy
311 N. Aberdeen St., 3rd Fl.
100 S. King St., St. 100
Chicago, IL 60607
Seattle, WA 98104
O: 312.243.5900
O: 312-243-5900
[e-mail]
[e-mail]
*Verified petitions for permission to practice forthcoming
Counsel for Plaintiff Craig Farah, Personal Representative
of the Estate of Nicholas Farah

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CERTIFICATE OF SERVICE

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I, Luke A. Busby, an attorney, hereby certify that on May 27, 2020, I filed
the foregoing via CM/ECF, which effected service on all counsel of record. I further
certify that I will ensure that Defendant Collin Petrielius receives a copy of the
foregoing at the time that he is served with notice of this lawsuit pursuant to Rule 4
of the Federal Rules of Civil Procedure.

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/s/ Luke A Busby
Designated Resident Nevada Counsel
for Plaintiff

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Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 6 of 14

Exhibit A
Verified Petition of David Owens

Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 7 of 14

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

Craig Farah, Personal Representative of the
Estate of Nicholas Farah

LVPMD, et al.,

20-cvcv-604
VERIFIED PETITION FOR
PERMISSION TO PRACTICE
IN THIS CASE ONLY BY
ATTORNEY NOT ADMITTED
TO THE BAR OF THIS COURT
AND DESIGNATION OF
LOCAL COUNSEL

David Owens

Loevy & Loevy
100 S. King Street #100-748
Seattle
312-243-5900

Plaintiff, Craig Farah

Washington
[e-mail]

98104

Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 8 of 14

5/9/2013
Illinois

1/13/2011
9/5/2018
5/11/2011
5/9/2013
1/11/2013
7/18/2014
1/25/2015
8/7/2015
6/23/2017
11/23/2015
1/14/2016
9/5/2018
10/30/2018
9/26/2018

State of California
State of Washington
7th Circuit Court of Appeals
US District Court for the ND Illinois
US District Court for the ND Indiana
US District Court for the CD Illinois
US District Court for the ND Ohio
US District Court for the WD Wisconsin
US District Court of ED Wisconsin
US District Court for the SD Texas
Central District of Califronia
Western District of Washington
5th Circuit Court of Appeals
9th Circuit Court of Appeals

none

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275030
53856
none
none
none
none
none
none
none
none
none
none
none
none

Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 9 of 14

none

none

8/26/2016

Woods v. Reno

US District Court of NV

Granted

8/28/2019

Lobato v. LVMPD

US District Court of NV

Granted

3

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Case 2:20-cv-00604-RFB-VCF Document 18 Filed 06/19/20 Page 11 of 14

10319

18th day of June, 2020.

[e-mail]

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