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Doe v. Clark County

United States District Court, D. Nevada

January 10, 2018

S.H. JOHN DOE, a minor child, by and through his Natural Parent and Legal Guardian, A.O. JANE DOE, an Individual; A.O. JANE DOE, Individually; Plaintiffs,
v.
CLARK COUNTY, a political subdivision of the State of Nevada; KEVIN BROWN, an Individual; JULIANE HUGHES, an Individual; EAGLE QUEST OF NEVADA, INC., a Nevada Corporation; EAGLE QUEST, a Nevada Domestic Corporation; IVAN RAY TIPPETTS, an Individual; LESLIE TIPPETTS, an Individual; SHERA WILLIAMS, an Individual; TOMISHA HORN, an Individual; ILIA HAMPTON, LCSW, QMPH, an Individual; TRENT HANSEN, LCSW, an Individual; Defendants

          LAGOMARSINO LAW, ANDRE M. LAGOMARSINO, ESQ. Nevada Bar No. 6711 Melanie L. Thomas, Esq. Nevada Bar No. 12576, Attorneys for Plaintiff

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI, THOMAS D. DILLARD, JR. ESQ. Nevada Bar No. 6270, Attorneys for Defendants Clark County, Kevin Brown and Juliane Hughes

          JOHN F. BEMIS, ESQ. Nevada Bar No. 9509 SARAH S. SILVERMAN, ESQ. Nevada Bar No. 13624 HALL PRANGLE & SCHOONVELD, LLC, Attorneys for Defendants Eagle Quest of Nevada, Inc., Eagle Quest, Ivan Ray Tippetts, Leslie Tippetts, Ilia Hampton, LCSW, QMPH, and Trent Hansen, LCSW

          STIPULATION AND ORDER TO DISMISS DEFENDANTS ILIA HAMPTON AND TRENT HANSEN WITH PREJUDICE

         IT IS HEREBY STIPULATED and agreed by and between counsel that:

         1. ILIA HAMPTON was an employee/agent of EAGLE QUEST and was acting in the course and scope of her employment at all times during S.H. JOHN DOE's foster care placement. The parties agree that HAMPTON was acting in her individual and official capacity.

         2. Defendant EAGLE QUEST is liable for all acts and/or omissions of ILIA HAMPTON, attributed to her by a finder of fact. This does not mean that Plaintiffs may not pursue any other Defendants in this litigation on the basis of HANSEN's acts.

         3. Nothing in this stipulation will limit the evidence admitted at trial of acts and/or omissions of ILIA HAMPTON. Nor will this stipulation, alone, limit the Plaintiffs' ability to recover against any other Defendants in this case in any way.

         4. That Defendant ILIA HAMPTON may be dismissed, with prejudice, from the instant litigation in case 2:17-cv-02380, with each party to bear their own attorneys' fees and costs.

         5. TRENT HANSEN was an employee/agent of EAGLE QUEST and was acting in the course and scope of his employment at all times during S.H. JOHN DOE's foster care placement. The parties agree that HANSEN was acting in his individual and official capacity.

         6. Defendant EAGLE QUEST is liable for all acts and/or omissions of TRENT HANSEN, attributed to him by a finder of fact. This does not mean that Plaintiffs may not pursue any other Defendants in this litigation on the basis of HANSEN's acts.

         7. Nothing in this stipulation will limit the evidence admitted at trial of acts and/or omissions of TRENT HANSEN. Nor will this stipulation, alone, limit the Plaintiffs' ability to recover against any other Defendants in this case in any way.

         8. That Defendant TRENT HANSEN may be dismissed, with prejudice, from the instant litigation in case 2:17-cv-02380, with each party to bear their own attorneys' fees and costs.

         IT IS ...


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