Go v. Clark County Department of Air Quality

• Court: District Court, D. Nevada
• Decided: February 11, 2021
• Docket: 2:19-cv-01775
• Status: Unknown

Opinion

1 || Burke Huber Nevada State Bar No. 10902 2 || RICHARD HARRIS LAW FIRM 801 South 4" Street 3 || Las Vegas, Nevada 89101 Tel: (702) 444-4444 4 || Email: burke@richarcharrislaw.com Attorneys for Plaintiffs 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 ELAINE GO, an individual, 9 Plaintiffs, Case No. 2:19-cv-01775-RFB-DJA 10 VS. 11 || CLARK COUNTY, a political subdivision; TED LENDIS, an individual; SHAWN STIPULATION TO EXTEND 12 || MCCRARY an individual, MARCI DEADLINE FOR PLAINTIFF TO FILE HENSON, an individual; LETTY BONILLA, RESPONSE TO DEFENDANT’S 13 an individual; SANDRA JEANTETE, an MOTION FOR SUMMARY individual, DOES 1 through 10; ROE JUDGMENT 14 || ENTITIES 11 through 20, inclusive jointly and severally, (SECOND REQUEST) 15 Defendants. 16 7 IT IS HEREBY STIPULATED by and between Plaintiffs, through counsel Burke Huber, a 18 the Richard Harris Law Firm, and Defendants, through their counsel Scott Davis, that Plaintiff shal 19 have an extension to February 17, 2021 to file a response to Defendant’s Motion for Summar 0) Judgment. This Stipulation is submitted and based upon the following: 7 1. On January 6, 2021, Defendants filed a motion for summary judgment. [ECF Nc 73 40]. 2. On January 20, 2021, Plaintiff and Defendant stipulated to allow Plaintiff unti 45 February 10, 2021 to file a response in opposition. [ECF No. 65]. 6 3. Plaintiff's counsel, Mr. Huber, had a trial in Orange County the first week o 47 February that consumed a tremendous amount of time. 28

1 4. Mr. Huber has been working to catch up on workload that piled up while he wa 2 || preparing for trial and also actually in trial. 3 5. Adding to complications, Plaintiff's counsel’s office recently swapped out it 4 || attorney software and the time to learn new processes and also locate files has increased delays.. 5 6. Plaintiff's counsel continues to homeschool three children that has upended his worl 6 || schedule. 7 7. Because of the above listed problems, Mr. Huber requested from Mr. Davis that h 8 || stipulate to an additional seven (7) days, or up to and including, February 17, 2021 to file a respons 9 || to the motion for summary judgment and he graciously agreed. 10 8. This request is made in good faith and not for the purpose of delay. 11 9, This is the first request for an extension of time. 12 || Dated this 10" day of February 2021. 13 RICHARD HARRIS LAW FIRM 14 15 /s/ Burke Huber By: _/s/Scott Davis □□□ ON Scott R. Davis 16 Burke Huber, Bar No. 10902 Nevada Bar No. 10019 17 801 S. Fourth Street 500 S. Grand Central Parkway, Ste. 5075 Las Vegas, Nevada 89101 Las Vegas, Nevada 18 Attorney for Plaintiffs Attorneys for Defendants 19 20 21 || ORDER 22 |! IT IS SO ORDERED: 23 24 A< □ 95 || RICHA LWARE, Il United States District Court 26 |/DATED this 11th day of February, 2021. 27 28