Ward v. City of Henderson, Nevada

Filing 29

ORDER Granting 27 Stipulation Regarding Answer to Current Complaint and Response to Anticipated First Amended Complaint. Signed by Magistrate Judge Nancy J. Koppe on 6/3/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:20-cv-02331-JAD-NJK Document 27 Filed 06/02/21 Page 1 of 2

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GARG GOLDEN LAW FIRM
ANTHONY B. GOLDEN, ESQ.
Nevada Bar No. 9563
WHITNEY J. SELERT, ESQ.
Nevada Bar No. 5492
CHARLES J. LEE, ESQ.
Nevada Bar No. 13523
3145 St. Rose Parkway, Suite 230
Henderson, Nevada 89052
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Counsel for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT COURT OF NEVADA

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BRIDGET WARD,

CASE NO.: 2:20-cv-02331-JAD-NJK
Plaintiff,

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STIPULATION AND [PROPOSED]
ORDER REGARDING ANSWER TO
CURRENT COMPLAINT AND
RESPONSE TO ANTICIPATED FIRST
AMENDED COMPLAINT

vs.
CITY OF HENDERSON, NEVADA; and
DOES 1 through X

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[FIRST REQUEST]

Defendant.

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Plaintiff Bridget Ward and Defendant City of Henderson, Nevada, by and through their
respective counsel of record, do hereby stipulate and agree as follows:
1.

On May 21, 2021, the Court entered an order (ECF No. 25) granting in part and

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denying in part Defendant’s Motion to Dismiss (ECF No. 8) and allowing Plaintiff until June 11,

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2021 leave to file an amended complaint on those claims dismissed without prejudice.

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GARG GOLDEN
LAW FIRM
3145 St. Rose Parkway
Suite 230
Henderson, Nevada 89052
[phone]

2.

On May 26, 2021, the parties attended a continued Early Neutral Evaluation

Session but did not resolve this case (ECF No. 26).
3.

Counsel have conferred, and Plaintiff does intend to file an amended complaint by

the June 11, 2021 deadline.
4.

In light of the impending amended complaint filing, and to avoid unnecessary
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Case 2:20-cv-02331-JAD-NJK Document 27 Filed 06/02/21 Page 2 of 2

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expenditure of fees and time, the parties agree that Defendant, with the Court’s approval, may

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forego filing an answer to the remaining claims in the current complaint (ECF No. 1), which

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answer would be due on June 4, 2021 per Fed. R. Civ. Pro. 12(a)(4)(A).

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5.

Instead, Defendant will file only a response to the impending amended complaint

within the timelines set forth in the Rules.

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6.

This is the first request to modify these deadlines.

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7.

This stipulation is not made for the purposes of delay but is intended to be made

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with good cause to avoid unnecessary and duplicative work causing extra fees to be incurred by

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the parties.

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Dated this 2nd day of June 2021.

Dated this 2nd day of June, 2021.

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FOX ROTHSCHILD LLP

GARG GOLDEN LAW FIRM

By: /s/ Colleen E. McCarty_______
COLLEEN E. MCCARTY, ESQ.
Nevada Bar No. 13186
1980 Festival Plaza Drive, Suite 700
Las Vegas, Nevada 89123
[phone]
Counsel for Plaintiff Bridget Ward

By: /s/ Anthony B. Golden_____
ANTHONY B. GOLDEN, ESQ.
Nevada Bar No. 9563
3145 Saint Rose Parkway, Suite #230
Henderson, Nevada 89052
[phone]
Counsel to Defendant City of Henderson,
Nevada

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IT IS SO ORDERED.

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___________________________________________
UNITED STATES MAGISTRATE JUDGE

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June 3, 2021
DATED:____________________________________

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GARG GOLDEN
LAW FIRM
3145 St. Rose Parkway
Suite 230
Henderson, Nevada 89052
[phone]

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