Frudden et al v. Pilling et al

Filing 108

ORDER granting ECF No. 107 Unopposed Motion for Extension of Time to File Reply to ECF No. 104 Motion for Attorney Fees. Reply due by 2/26/2018. Signed by Judge Robert C. Jones on 2/8/2018. (Copies have been distributed pursuant to the NEF - KW)

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Mary Frudden, Esq.
Nevada State Bar No. 3973
1902 Carter Dr.
Reno, NV 89509
775-324-7078
[e-mail]
On behalf of Plaintiffs
Jon E. Frudden as parent and
guardian of John Doe and Jon
E. Frudden as parent and guardian
of Jane Doe

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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JON E. FRUDDEN, as parent and guardian of
his minor children JOHN DOE and JANE
DOE,
Plaintiffs,

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vs.

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KAYANN PILLING, et al.

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Case No.: 3:11-cv-00474-RCJ-WCG

MOTION AND STIPULATION
FOR EXTENSION OF TIME TO FILE
REPLY IN SUPPORT OF REQUEST FOR
ATTORNEY’S FEES AND IN REPLY TO
DEFENDANTS’ RESPONSE TO REQUEST
FOR ATTORNEY’S FEES ON APPEAL

Defendants.

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(First Request and Stipulation)
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JON E. FRUDDEN, as parent and guardian of his minor children, JOHN DOE AND

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JANE DOE, by and through his attorney, Mary Frudden, Esq., pursuant to LR IA 6-1 and 6-2,

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hereby files the following Motion and Stipulation for Extension of Time to File Reply in Support

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of Request for Attorney’s Fees and in Reply to Defendants’ Response to Request for Attorney’s

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Fees (First Request). The Request for Attorney’s Fees on Appeal was initially timely filed with

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the Ninth Circuit Court of Appeals in Frudden v. Pilling, No. 15-15448 on January 17, 2018

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(Dkt. 54); (Doc. 104). The Ninth Circuit transferred the Request on January 29, 2018 (Dkt. 55);

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(Doc. 102). By Minute Order dated January 29, 2018, the District Court sua sponte extended the

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time for Defendants/Appellees (hereafter Defendants) to file a response to the fee motion until

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February 12, 2018. Plaintiffs request an extension of time to file the Reply until February 26,

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2018 because Plaintiffs’ counsel Mary Frudden is the chaperone for several soccer players
Motion and Stipulation for Extension of Time to File Reply in Support of Request for Attorney’s Fees
and in Reply to Defendants’ Response to Request for Attorney’s Fees

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scheduled to play in the Mayor’s Cup International Showcase in Las Vegas, Nevada February

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17-19, 2018 for the Reno Strikers boys’ team and will be driving to Las Vegas with the players

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on Friday February 16 and driving back to Reno on either Monday February 19 or Tuesday

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February 20, 2018. Because of her commitment as a chaperone, Mary Frudden, Esq. will have

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insufficient time to prepare the anticipated Reply. This Motion and Stipulation is entered into in

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good faith and not for the purpose of delay.

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Dated this 7th day of February, 2018.

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By: s/ Mary Frudden_______
MARY FRUDDEN, ESQ.
Nevada State Bar No. 3973
1902 Carter Dr.
Reno, NV 89501
Telephone: [phone]
[e-mail]
On Behalf of Plaintiffs
Jon E. Frudden as parent and guardian
of John Doe and Jon E. Frudden as
parent and guardian of Jane Doe

By:

s/ Sara Almo________________
SARA ALMO, ESQ.
Nevada State Bar No. 11899
General Counsel
Washoe County School District
425 E. Ninth Street
Reno, NV 89512
Telephone: [phone]
[e-mail]
On Behalf of Defendants Washoe
County School District and Roy
Gomm Elementary School ParentFaculty Association, Inc.

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IT IS SO ORDERED: _____________________________
United States District Judge
DATED: _________________
February 8, 2018.

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Motion and Stipulation for Extension of Time to File Reply in Support of Request for Attorney’s Fees
and in Reply to Defendants’ Response to Request for Attorney’s Fees

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CERTIFICATE OF SERVICE

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I hereby certify that the foregoing document was filed electronically with the Clerk of the

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Court and served upon the Defendants’ counsel via the electronic filing system and the Notice of

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Electronic Filing indicates service as follows:

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Sara Almo at [e-mail]

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Counsel for Defendants Washoe County School District and Roy Gomm Elementary

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School Parent-Faculty Association, Inc.

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Dated this 7th day of February, 2018.

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s/ Mary Frudden___________________
Mary Frudden, Esq.

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Motion and Stipulation for Extension of Time to File Reply in Support of Request for Attorney’s Fees
and in Reply to Defendants’ Response to Request for Attorney’s Fees

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