Enos v. Douglas County et al

Filing 131

ORDER granting ECF No. 128 Stipulation. Joint Pretrial Order due by 5/20/2020. Signed by Chief Judge Miranda M. Du on 4/8/2020. (Copies have been distributed pursuant to the NEF - LW)

1 WILLIAM J. GEDDES
Nevada Bar No. 6984

2 KRISTEN R. GEDDES
Nevada Bar No. 9027

3 THE GEDDES LAW FIRM, P.C.
1575 Delucchi Lane, Suite 206

4 Reno, NV 89502

Phone: [phone]
5 Fax: [phone]
Email: [e-mail]
6 Email: [e-mail]
Attorneys for Plaintiff John Enos

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RAELENE K. PALMER

8 Nevada Bar No. 8602

THE PALMER LAW FIRM, P.C.

9 5550 Painted Mirage Road, Suite 320
Las Vegas, Nevada 89149

10 Phone: [phone]

Email: [e-mail]

11 Attorneys for Plaintiff John Enos
The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

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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-CLB

Plaintiff,

16 vs.
STIPULATION AND [PROPOSED]
ORDER TO ENLARGE TIME TO FILE
PROPOSED JOINT PRETRIAL ORDER

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.

(First Request)
Defendants.

COMES NOW Plaintiff JOHN ENOS and Defendants DOUGLAS COUNTY, SCOTT SHICK,
and VICTORIA SAUER-LAMB, by and through their undersigned attorneys of record, and hereby
request a 30-day enlargement of time for the parties to file their proposed Joint Pretrial Order (JPTO).
The proposed JPTO is currently due on Monday, April 20, 2020. At this time, the parties believe that
additional time, between 30-60 days, is necessary to submit the proposed JPTO; however, the parties’
first request is limited to requesting 30 additional days through and including Wednesday, May 20,
2020 to file the proposed JPTO.

The Coronavirus Disease (COVID-19) pandemic has impaired

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1 counsel’s ability to prepare the JPTO. For example, one attorney for Plaintiff is located in Las Vegas,
2 where COVID-19 case are much higher and would require out-of-town counsel to travel to Washoe
3 County. As well, due to Governor Sisolak’s social distancing guidelines and directives, other counsel
4 have been subject to office closures and staff reductions, hindering counsel’s ability to do work
5 necessary to prepare the JPTO. Due to the same social distancing guidelines, there is also great
6 uncertainty as to the availability of the parties, counsel, witnesses and potential jurors to interact at a
7 trial. What’s more, it is not known when normal Court operations will resume in light of the exigent
8 circumstances and temporary restrictions regarding court operations imposed by Temporary General
9 Order 2020-04. At the time of the issuance of Temporary General Order 2020-04 the Court noted there
10 were 26 reported cases of COVID-19. See generally, Temporary General Order 2020-04, fn. 1. As of
11 the present date of filing the instant Stipulation, the number of reported cases in Washoe County is 309,
The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

12 which continues to increase daily.1 Since the issuance of Temporary General Order 2020-04,
13 Governor Sisolak recently extended the closure of businesses and schools from April 16, 2020 until at
14 least April 30, 2020. While nationwide it has been reported that COVID-19 cases are expected to peak
15 within the next week to ten days, recent reports concerning Washoe County have modelled the peak of
16 COVID-19 cases in Washoe County as possibly coming near the end of May.2 Consequently, it is
17 unknown at this time when the Court will resume normal operations, including setting trials, which
18 further frustrates the parties’ attempts to arrive at good-faith representations of availability of trial
19 counsel, the parties and witnesses for trial.
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See https://www.rgj.com/story/news/2020/04/07/washoe-county-coronavirus-update-renolas-vegas-nevada/2959245001/ (last accessed April 7, 2020).
28 2 See fn. 1.

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1 This is the parties’ first request to extend this deadline, and the parties submit that this request is not for
2 the purpose of undue delay.
3 Dated this 7th day of April 2019.
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THE GEDDES LAW FIRM, P.C.
By:
KRISTEN R. GEDDES
Nevada Bar Number 9027
1575 Delucchi Lane, Suite 206
Reno, Nevada 89502
Phone: [phone]
Attorneys for Plaintiff John Enos

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th
11 Dated this 7 day of April 2020.

THORNDAL ARMSTRONG DELK
BALENBUSH & EISINGER

The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, NV 89502
Phone [phone]

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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

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II.

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ORDER
IT IS SO ORDERED.
Dated: April 8, 2020

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UNITED STATES DISTRICT JUDGE

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