Enos v. Douglas County et al

Filing 59

ORDER granting ECF No. 58 Stipulation for Extension of Time for Plaintiff to file opposition to ECF No. 57 Defendants' Motion to Dismiss. Response due by 1/16/2018. Signed by Judge Miranda M. Du on 12/28/2017. (Copies have been distributed pursuant to the NEF - LH)

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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6 RAELENE K. PALMER
Nevada Bar No. 8602

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

8 Las Vegas, Nevada 89104
Phone: [phone]

9 Fax: [phone]

Email: [e-mail]

10 Attorneys for Plaintiff John Enos

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

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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

Plaintiff,

15 vs.

STIPULATION AND PROPOSED ORDER
FOR ENLARGEMENT OF TIME

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

For Plaintiff to File Opposition
To Defendants Young and Gibbons’
Motion to Dismiss (ECF 057)

17 Juvenile Probation Officer of the Juvenile

Probation Department; VICTORIA SAUER-

18 LAMB, Supervisor of the Juvenile Probation

Department; NATHAN TODD YOUNG, Judge

19 of the Ninth Judicial District Court of Nevada;

(First Request)

MICHAEL GIBBONS, Former Judge of the

20 Ninth Judicial District Court of Nevada; DOE
GOVERNMENTAL ENTITIES 1-10, DOE

21 BUSINESS ENTITIES 1-10; DOE
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INDIVIDUALS 4-50.
Defendants.
The parties to this action, by and through their undersigned counsel of record hereby stipulate

25 that Plaintiff may have a one-week extension of time, through and including Tuesday, January 16,
26 2018, to file his opposition to Defendants Young and Gibbons’ Motion to Dismiss (ECF 057). This is
27 the first request for such an extension. The original deadline to file this opposition is Tuesday, January
28 9, 2018. The reason Plaintiff needs additional time to file this brief is because his counsel will be out of
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1 the office on a pre-planned vacation at the end of December 2017 through the first week in January
2 2018, and he will need additional time to prepare the opposition brief. This Stipulation is not offered
3 for any dilatory or improper purpose.
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Dated this 28th day of December 2018.

Dated this 28th day of December 2018.

6

ADAM PAUL LAXALT
Attorney General

THE GEDDES LAW FIRM, P.C.

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Electronic Signature Authorized

8

Steve Shevorski

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By:

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
KATLYN M. BRADY,
Nevada Bar No. 14173
Deputy Attorney General
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

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, January 16, 2018, to file his opposition to Defendants Young
and Gibbons’ Motion to Dismiss (ECF 057).

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Attorneys for Plaintiff John Enos

ORDER

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WILLIAM J. GEDDES
Nevada Bar Number 6984
8600 Technology Way, Suite 107
Reno, Nevada 89521
[phone]

Dated:

December 28, 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 December 28,

3 2017, I caused to be served a copy of the foregoing Stipulation and Proposed Order for Enlargement of
4 Time for Plaintiff to File Opposition to Defendants Young and Gibbons’ Motion to Dismiss (ECF 057)
5 (First Request), by electronic filing with the Court’s Pacer e-filing system, addressed to:
6 Katherine F. Parks, Esq.
State Bar No. 6227

7 THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER
6590 S. McCarran Blvd, Suite B

8 Reno, Nevada 89509
(775) 786—2882

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Attorneys for Defendants Douglas County, Scott Shick, and Victoria Sauer-Lamb
Steve Shevorski, Head of Complex Litigation

11 Michelle Di Silvestro Alanis, Deputy Attorney General
The Geddes Law Firm, P.C.
8600 Technology Way, Suite 107
Reno, NV 89521
Phone [phone]

Katlyn M. Brady, Deputy Attorney General

12 STATE OF NEVADA OFFICE OF THE ATTORNEY GENERAL
555 E. Washington Avenue, Ste. 3900
13 Las Vegas, NV 89101-1068
Phone: [phone]

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Attorneys for Defendants Nathan Todd Young and Michael Gibbons

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

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