Enos v. Douglas County et al

Filing 113

ORDER approving ECF No. 112 Stipulation re ECF Nos. 106 , 107 Motions for Partial Summary Judgment: Responses due by 9/3/2019. Signed by Judge Miranda M. Du on 8/29/2019. (Copies have been distributed pursuant to the NEF - KR)

1 WILLIAM J. GEDDES
Nevada Bar No. 6984

2 KRISTEN R. GEDDES
Nevada Bar No. 9027

3 THE GEDDES LAW FIRM, P.C.
8600 Technology Way, Suite 107

4 Reno, Nevada 89521

Phone: [phone]
5 Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff John Enos
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7 RAELENE K. PALMER
Nevada Bar No. 8602

8 GALLIAN WELKER & BECKSTROM, L.C.
540 E. St. Louis Avenue

9 Las Vegas, Nevada 89104
Phone: [phone]

10 Fax: [phone]

Email: [e-mail]

The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

11 Attorneys for Plaintiff John Enos
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

14 JOHN ENOS, an individual,
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CASE NO: 3:17-cv-00095-MMD-CBC

Plaintiff,

16 vs.

STIPULATION AND [PROPOSED]
ORDER TO ENLARGE TIME (By Two
Business Days) TO FILE OPPOSITION TO
MOTIONS FOR PARTIAL SUMMARY
JUDGMENT
[ECF 106 and 107]

17 DOUGLAS COUNTY, a political subdivision
of the State of Nevada; SCOTT SHICK, Chief

18 Juvenile Probation Officer of the Juvenile
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Probation Department; et al.

(Third Request)

Defendants.

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COMES NOW Plaintiff JOHN ENOS and Defendants DOUGLAS COUNTY, SCOTT SHICK,

23 and VICTORIA SAUER-LAMB, by and through their undersigned attorneys of record, and hereby
24 request a 2-business-day enlargement of time for the parties to file their oppositions to the motions for
25 partial summary judgment (ECF Nos. 106 and 107), filed on July 12, 2019. These oppositions are
26 currently due on Friday, August 30, 2019, and the parties request an additional two business days,
27 through and including Tuesday, September 3, 2019, to file their oppositions to the motions for
28 partial summary judgment. This is the parties’ third request to extend this deadline. The parties submit
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1 that this third request is not for the purpose of undue delay, but arises because Plaintiff’s Counsel
2 Kristen Geddes, who is preparing the opposition brief for Plaintiff John Enos, is physically ill today,
3 Thursday, August 29, 2019, and she is absent from work and, thus, will not be able to complete
4 Plaintiff’s opposition brief by tomorrow. Further, it is not known whether Ms. Geddes’ illness will
5 persist through Friday, August 30, 2019. Accordingly, the Parties request two additional business days
6 to file these opposition briefs.
7 Dated this 29th day of August 2019.
8
9

THE GEDDES LAW FIRM, P.C.
By:
WILLIAM J. GEDDES
Nevada Bar Number 6984
8600 Technology Way, Suite 107
Reno, Nevada 89521
Phone: [phone]
Attorneys for Plaintiff John Enos

10

The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

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13 Dated this 29th day of August 2019.
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15

THORNDAL ARMSTRONG DELK
BALENBUSH & EISINGER

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Electronic Signature Authorized

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/s/
By:
Katherine F. Parks, Esq.
6590 S. McCarran Blvd, Suite B
Reno, Nevada 89509
Phone: (775) 786—2882
Attorneys for Defendants Douglas
County and Scott Shick

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II.

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ORDER
IT IS SO ORDERED.
Dated: August 29, 2019

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UNITED STATES DISTRICT JUDGE

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CERTIFICATE OF SERVICE
I hereby certify that I am an employee of the Geddes Law Firm, P.C., and that on August 29,

3 2019, I caused to be served a copy of the foregoing Stipulation and [Proposed] Order to Enlarge Time
4 (By Two Business Days) To File Opposition to Motions For Partial Summary Judgment [ECF 106 and
5 107] by electronic filing with the Court’s PACER e-filing system, addressed to:
6 Katherine F. Parks, Esq.

THORNDAL ARMSTRONG DELK BALENBUSH & EISINGER

7 6590 S. McCarran Blvd, Suite B
Reno, Nevada 89509

8 Phone: (775) 786—2882

Attorneys for Defendants Douglas County, Scott Shick, and Victoria Sauer-Lamb

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10

The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

11

WILLIAM J. GEDDES
An employee of the Geddes Law
Firm, P.C.

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