Enos v. Douglas County et al

Filing 18

ORDER GRANTING ECF No. 17 Stipulation : Response to ECF No. 5 MOTION to Dismiss due by 6/9/2017. Signed by Judge Miranda M. Du on 6/1/2017. (Copies have been distributed pursuant to the NEF - DRM)

1 WILLIAM J. GEDDES
Nevada Bar No. 6984

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

3 Reno, Nevada 89521

Phone: [phone]

4 Fax: [phone]

Email: [e-mail]
Attorneys for Plaintiff John Enos
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

8 JOHN ENOS, an individual,
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CASE NO: 3:17-cv-00095-MMD-VPC

Plaintiff,

10 vs.

STIPULATION AND PROPOSED ORDER
FOR ENLARGEMENT OF TIME

11 DOUGLAS COUNTY, a political subdivision
The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

of the State of Nevada; SCOTT SHICK, Chief

For Plaintiff to File Opposition
To Defendant State of Nevada’s
Motion to Dismiss (ECF 005)

12 Juvenile Probation Officer of the Juvenile
Probation Department; THE STATE OF

13 NEVADA ex rel. The Ninth Judicial District
Court of the State of Nevada; DOE

(Second Request)

14 GOVERNMENTAL ENTITIES 1-10, DOE
BUSINESS ENTITIES 1-10; and DOE

15 INDIVIDUALS 1-50.
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Defendants.

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The parties to this action, by and through their undersigned counsel of record hereby stipulate

19 that Plaintiff may have a three (3)-day extension of time, through and including Friday, June 9,
20 2017, to file his opposition to Defendant State of Nevada’s Motion to Dismiss (ECF 005). This is the
21 second request for such an extension. The current deadline to file this opposition is Tuesday, June 6,
22 2017. The reason Plaintiff needs additional time to file this brief is because his counsel has had a very
23 congested calendar, his counsel’s office was closed on Memorial Day, and his counsel’s legal work for
24 a wrongful-death litigation that has taken longer than his counsel originally anticipated when requesting
25 the first extension of this filing deadline. Accordingly, Plaintiff will need a few days’ additional time to
26 file the opposition brief.
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28 / / /
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1 This Stipulation is not offered for any dilatory or improper purpose.
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Dated this 1st day of June 2017.

Dated this 1st day of June 2017.

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ADAM PAUL LAXALT
Attorney General

THE GEDDES LAW FIRM, P.C.

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Electronic Signature Authorized

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Steve Shevorski

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By:

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

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/s/
STEVE SHEVORSKI
Nevada Bar No. 8256
Head of Complex Litigation
MICHELLE DI SILVESTRO ALANIS
Nevada Bar No. 10024
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Avenue, Ste. 3900
Las Vegas, NV 89101-1068
[phone] (phone)
Attorneys for State of Nevada
ex rel. Ninth Judicial District Court
of the State of Nevada

ORDER

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THE COURT, having considered the preceding Stipulation and GOOD CAUSE appearing

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therefor, GRANTS the Stipulation. IT IS HEREBY ORDERED that Plaintiff shall have additional
time, through and including Tuesday, June 9, 2017, to file his opposition to Defendant State of
Nevada’s Motion to Dismiss (ECF 005).

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WILLIAM J. GEDDES
Nevada Bar Number 6984
8600 Technology Way, Suite 107
Reno, Nevada 89521
[phone]
Attorneys for Plaintiff John Enos

Dated:

June 1, 2017

IT IS SO ORDERED

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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 June 1, 2017,

3 I caused to be served a copy of the foregoing Stipulation and Proposed Order for Enlargement of Time
4 for Plaintiff to File Opposition to Defendant State of Nevada’s Motion to Dismiss (ECF 005)(Second
5 Request), by electronic filing with the Court’s Pacer e-filing system, addressed to:
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The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

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Adam Paul Laxalt
Attorney General
Steve Shevorski
Nevada Bar No. 8256
Head Of Complex Litigation
Michelle Di Silvestro Alanis
Nevada Bar No. 10024
Deputy Attorney General
State of Nevada Office of the Attorney General
555 E. Washington Avenue, Ste. 3900
Las Vegas, NV 89101-1068
[phone] (phone)
Attorneys for State of Nevada
ex rel. Ninth Judicial District Court of the State of Nevada

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

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