Schreckengost et al v. State of Nevada (NDOC) et al

Filing 74

ORDER granting ECF No. 73 Stipulation : Responses to ECF Nos. 69 , 70 Motions to Dismiss due by 11/30/2020. Signed by Chief Judge Miranda M. Du on 11/20/2020. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:19-cv-00659-MMD-CLB Document 74 Filed 11/20/20 Page 1 of 3

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, Nevada 89521

Phone: [phone]
5 Fax: [phone]
Email: [e-mail]
6 Email: [e-mail]
Attorneys for Plaintiffs Ron Schreckengost and Elizabeth Walsh

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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10 RON SCHRECKENGOST, an individual, and

CASE NO: 3:19-cv-00659-MMD-CLB

ELIZABETH WALSH, an individual,

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

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Plaintiff,

STIPULATION, REQUEST, AND
[PROPOSED] ORDER
ENLARGING TIME FOR
PLAINTIFFS TO OPPOSE DEFENDANTS’
TWO MOTIONS TO DISMISS
(ECF 069 and ECF 070)

vs.

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THE STATE OF NEVADA ex rel. the
NEVADA DEPARTMENT OF
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CORRECTIONS; and PERRY RUSSELL, an
15 individual.

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(SECOND REQUEST)

Defendants.

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

20 that Plaintiffs may have a 10-day extension of time to file their opposition briefs to Defendants’ two
21 motions to dismiss (ECF 069 and ECF 070), through and including Monday, Nov. 30, 2020,
22 Pursuant to this stipulation, the parties hereby request that the Court grant this enlargement of time.
23 This is the second request for such an extension. The current deadline to file these two opposition
24 briefs is Friday, November 20, 2020, which deadline has not yet run. The reasons that additional time
25 is requested here is because Plaintiff’s Counsel underestimated the amount of time it would take to
26 complete these opposition briefs, when first requesting an extension, given the fact that he had been and
27 continued to be quite busy with many pressing matters in other cases. As well, the offices of Plaintiff’s
28 Counsel will be closed for the Thanksgiving Holiday, November 26-27, 2020, which necessitates an
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Case 3:19-cv-00659-MMD-CLB Document 74 Filed 11/20/20 Page 2 of 3

1 extension through the Monday, November 30, 2020, immediately after the holiday. This stipulation
2 and request are not made for any dilatory or improper purpose.
3 Dated this 18th Day of November.

THE GEDDES LAW FIRM, P.C.

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WILLIAM J. GEDDES
Nevada Bar Number 6984
The Geddes Law Firm, P.C.
1575 Delucchi Lane, Suite 206
Reno, Nevada 89502
[phone]
Attorneys for Plaintiffs Ron
Schreckengost and Elizabeth
Walsh

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11 Dated this 18th Day of November .

AARON D. FORD
Nevada Attorney General

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/ Brandon R. Price
BRANDON R. PRICE
Senior Deputy Attorney General
Nevada Bar No. 11686
SCOTT H. HUSBANDS
Deputy Attorney General
Nevada Bar No. 11398
State of Nevada
Office of the Attorney General
5420 Kietzke Lane, Suite 202
Reno, NV 89511
[phone] (phone)
Attorneys for Defendants, State of
Nevada ex rel. its Department of
Corrections and
Perry Russell

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ORDER

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24 Dated: November 20, 2020

IT IS SO ORDERED

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UNITED STATES DISTRICT JUDGE

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Case 3:19-cv-00659-MMD-CLB Document 73 Filed 11/18/20 Page 3 of 3
74
11/20/20

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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 November

3 18, 2020, I caused to be served a copy of the foregoing Stipulation, Request, and [Proposed] Order
4 Enlarging Time for Plaintiffs to Oppose Defendants’ Two Motions to Dismiss (ECF 069 and ECF 070)
5 (Second Request), by filing the same with the Court’s electronic filing system (PACER), addressed to
6 the following:
7 AARON D. FORD
Nevada Attorney General

8 BRANDON R. PRICE

Senior Deputy Attorney General

9 SCOTT H. HUSBANDS

Deputy Attorney General

10 State of Nevada Office of the Attorney General
5420 Kietzke Lane, Suite 202

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

11 Reno, NV 89511

12 Attorneys for Defendants, State of Nevada
ex rel. its Department of Corrections and

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

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