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Doe v. City of Las Vegas

United States District Court, D. Nevada

June 7, 2019

JANE DOE, an Individual, Plaintiff,
v.
CITY OF LAS VEGAS, CITY OF HENDERSON, NATHAN HANNIG, an Individual, MARIO RUEDA, an Individual, RUBEN SANCHEZ, an Individual, JAMES SUAREZ, an Individual, JONATHAN CUFF, an Individual, JOSEPH “JOE” VANEK, an Individual, JAROD BARTO, an Individual, CODY RACINE, an Individual JASON TULLIS, an Individual, and ZACH YEOMAN, an Individual, WILLIAM MCDONALD, an Individual, and as an Individual, JON STEVENSON, an Individual, JOHN DOE #1, likely an Individual, DOES I -X; ROE CORPORATIONS I -X. Defendants.

          JENNY L. FOLEY, Ph.D., ESQ. Nevada Bar No. 9017 MARTA D. KURSHUMOVA, ESQ. Nevada Bar No. 14728 HKM EMPLOYMENT ATTORNEYS LLP Attorneys for Plaintiff

          HKM Employment Attorneys LLP Jenny L. Foley, Ph.D., Esq. Nevada Bar No. 9017

          Gabroy Law Offices Christian J. Gabroy, Esq. Nevada Bar No. 8805

          Law Office of Daniel Marks, Ltd.Adam M. Levine, Esq. Nevada Bar No. 4673

          Cook and Kelesis, Ltd. Marc P. Cook, Esq. Nevada Bar No. 4574

          STIPULATION AND ORDER TO EXTEND THE TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTION TO DISMISS (FIRST REQUEST)

          Gloria M. Navarro, Chief Judge.

         COMES NOW, the Plaintiff, JANE DOE (“Jane”), by and through her attorney, JENNY L. FOLEY, Ph.D., ESQ., of the law firm HKM EMPLOYMENT ATTORNEYS LLP, and Defendant, CITY OF LAS VEGAS, (“City of Las Vegas”), by and through their attorney, JACK ESLINGER, ESQ., of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, CITY OF HENDERSON, (“City of Henderson”), by and through their attorney, BRIAN R. REEVE, ESQ., of CITY OF HENDERSON CITY ATTORNEY'S OFFICE, Defendant, NATHAN HANNING, (“Nathan”) an Individual, by and through his attorney, DEANNA L. FORBUSH, ESQ., of MORRIS, POLICH & PURDY LLP, Defendant, MARIO RUEDA, (“Mario”) an Individual, by and through his attorney, ADAM M. LEVINE, ESQ., of LAW OFFICE OF DANIEL MARKS, LTD., Defendant, RUBEN SANCHEZ, (“Ruben”) an Individual, by and through his attorney, JACK O'ESLINGER, ESQ., of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, JAMES SUAREZ, (“James”) an Individual, by and through his attorney, JACK O' ESLINGER, ESQ. of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, JONATHAN CUFF, (“Jonathan”) an Individual, by and through his attorney, JACK O' ESLINGER, ESQ. of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, JOSEPH “JOE” VANEK, (“Joe”) an Individual, by and through his attorney, JACK O' ESLINGER, ESQ. of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, JAROD BARTO, (“Jarod”) an Individual, by and through his attorney, MARC P. COOK, ESQ., of COOK AND KELESIS, LTD., Defendant, CODY RACINE, (“Cody”) an Individual, by and through his attorney, CHRISTIAN JAMES GABROY, ESQ., of GABROY LAW OFFICES, Defendant, JASON TULLIS, (“Jason”) an Individual, by and through his attorney, ADAM M. LEVINE, ESQ., of LAW OFFICE OF DANIEL MARKS, LTD., Defendant, ZACH YEOMAN, (“Zach”) an Individual, by and through his attorney, ADAM M. LEVINE, ESQ., of LAW OFFICE OF DANIEL MARKS, LTD., Defendant, WILLIAM MCDONALD, (“William”) by and through his attorney, JACK O' ESLINGER, ESQ. of THE LAS VEGAS CITY ATTORNEY'S OFFICE, Defendant, JON STEVENSON, (“Jon”) an Individual, by and through his attorney, JACK O' ESLINGER, ESQ. of THE LAS VEGAS CITY ATTORNEY'S OFFICE, JOHN DOE #1, likely an Individual and hereby stipulate and agree as follows:

1. That the Response to the Defendants' Motions to Dismiss that are due on June 5, 2019; June 11, 2019 and June 14, 2019 collectively, and from the office of Daniel Marks, Ltd., Gabroy Law Offices and Cook and Kelesis, Ltd., will now be due on June 21, 2019.
2. That the Reply to the Response to the Defendant's Motions to Dismiss shall be due July 12, 2019.
3. This request for an extension of time is made in good faith and not for purpose of delay. This is the first request for an extension of time with respect to the Reply and Responses associated with Defendants' Motions.

         ORDER

         The Court having reviewed the foregoing STIPULATION AND ORDER TO EXTEND THE TIME FOR PLAINTIFF TO RESPOND TO DEFENDANTS' MOTION TO DISMISS in the above-entitled matter and for good cause appearing therefor, IT IS SO ORDERED that the Response to Defendants' Motions to Dismiss shall be due on June 21, 2019.

         IT IS SO ORDERED that the Reply to the Response to Defendants' Motions to Dismiss ...


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