-RAM UNITED STATES OF AMERICA V. JOHN C. CARPENTER, ET AL., No. 3:1999cv00547 - Document 377 (D. Nev. 2011)
Court Description: ORDER GRANTING 376 Unopposed Motion to Extend Deadline to File Reply. Defendant, Elko County, shall have until Tuesday, 7/12/2011, in which to file their Reply to the 351 Motion to Dismiss for Mootness. Signed by Judge Roger L. Hunt on 7/7/2011. (Copies have been distributed pursuant to the NEF - MLC)
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-RAM UNITED STATES OF AMERICA V. JOHN C. CARPENTER, ET AL. 1 2 3 4 5 6 7 8 9 10 11 Doc. 377 Mark Torvinen, Nevada Bar # 551 Elko County District Attorney 540 Court Street, 2nd Floor Elko, NV 89801 mtorvinen@elkocountynv.net 775) 738-3101 (phone) (775) 738-0810 (facsimile) Kristin A. McQueary, Nevada Bar # 4337 540 Court Street, 2nd Floor Elko, NV 89801 kmcqueary@elkocountynv.net (775) 738-3101 (phone) (775) 738-0810 (facsimile) Attorneys for Defendant Elko County 12 13 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 14 15 16 17 18 19 20 21 22 23 24 25 26 27 3:99-cv-547-RLH-RAM UNITED STATES OF AMERICA, Plaintiff-Counter-Defendant vs. UNOPPOSED JOHN C. CARPENTER MOTION TO EXTEND DEADLINE TO FILE REPLY Defendant, GRANT GERBER; O.Q. JOHNSON, Defendants, And COUNTY OF ELKO, Defendant THE WILDERNESS SOCIETY; GREAT OLD BROADS FOR THE WILDERNESS, Intervenors and Cross-claimants. Defendant. 28 DA#01981 -1- Dockets.Justia.com 1 2 COMES NOW, Defendant County of Elko, by and through its attorneys, MARK TORVINEN, District Attorney for the County of Elko, and KRISTIN A. MCQUEARY, Elko 3 4 County Chief Civil Deputy District Attorney, hereby moves to extend motion to extend 5 deadline to file reply in this case until Tuesday, July 12, 2011. (Docket NO. 351). The 6 Deadline is currently July 6, 2011. Elko County is unable to complete its Reply due to its 7 8 9 10 computer system not working, see attached. (Exhibit A Email). Elko County informed Courtroom Administrator, Jennifer Cotter of the technical difficulties yesterday by telephone. 11 12 13 14 15 16 Civil Division Caseworker Juliana Fisherman recreated the form in order to file this Motion to Continue. Based on the foregoing, Elko County respectfully requests that this Court extend the deadline in the Scheduling Order on Elko County’s Reply to Motion to Dismiss for Mootness. 17 Counsel for The Wilderness Society and The Great Old Broads For Wilderness (collectively 18 “TWS”), and United States have graciously advised that they do not object to the requested 19 extension of time. 20 21 Dated this 6th day of July, 2011. 22 MARK TORVINEN Elko County District Attorney 23 24 25 By: 26 27 28 _/S/ KRISTIN A. MCQUEARY ______ KRISTIN A. MCQUEARY Chief Civil Deputy District Attorney State Bar No. 4337 IT IS SO ORDERED. ___________________________________ UNITED DA#01981 STATES DISTRICT JUDGE -2- DATED: July 7, 2011 1 CERTIFICATE OF SERVICE 2 I hereby certify that on this 6th day of July, 2011, a true and correct copy of the 3 foregoing UNOPPOSED MOTION TO EXTEND DEADLINE TO FILE REPLY was filed via 4 the Court’s ECF system, with notification sent to the following: 5 6 7 8 9 10 11 Michael S. Freeman Attorney At Law 1400 Glenarm Pl., # 300 Denver, CO 80202 Henry Egghart Attorney at Law 317 S. Arlington Avenue Reno, NV 89501 Blaine Welsh Office of U.S. Attorney – Las Vegas 333 Las Vegas, NV 89101 Blaine.Welsh@usdoj.gov Grant Gerber Gerber Law Offices, LLP 491 Fourth Street Elko, NV 89801 agg@gerberlegal.com Holly A. Vance Assistant United States Attorney 100 W. Liberty Street, Suite 600 Reno, NV 89501 Demar Dahl Starr Valley Deeth, NV 89823 12 13 14 15 16 17 18 19 David W. Gehlert Trial Attorney Environmental & Natural Resources Division 999 18th Street, South Terrace, Suite 370 Denver, CO 80202 David. Gehlert@usdoj.gov 20 21 22 23 _/S/JULIANA FISHERMAN_______________ JULIANA FISHERMAN CASEWORKER 24 25 26 27 28 DA#01981 -3- 1 EXHIBIT A 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DA#01981 -4- 1 2 3 4 5 6 7 8 From: Gehlert, David (ENRD) [mailto:David.Gehlert@usdoj.gov] Sent: Tuesday, July 05, 2011 1:13 PM To: Michael Freeman; Kristin McQueary; Vance, Holly A. (USANV); gwoodberry Subject: RE: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) As does the US. From: Michael Freeman [mailto:mfreeman@earthjustice.org] Sent: Tuesday, July 05, 2011 2:13 PM To: 'Kristin McQueary'; Gehlert, David (ENRD); Vance, Holly A. (USANV); gwoodberry Subject: RE: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) That’s fine – we understand. 10 From: Kristin McQueary [mailto:kmcqueary@elkocountynv.net] Sent: Tuesday, July 05, 2011 2:04 PM To: Gehlert, David (ENRD); Vance, Holly A. (USANV); gwoodberry; Michael Freeman Subject: RE: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) 11 Counsel, 12 It struck me that I don’t have a way to generate a motion to continue either. If it is okay with all of you, I will call the Court Clerk. 9 13 14 15 16 17 18 Thanks, Kristin From: Gehlert, David (ENRD) [mailto:David.Gehlert@usdoj.gov] Sent: Tuesday, July 05, 2011 12:10 PM To: Michael Freeman; Kristin McQueary; Vance, Holly A. (USANV); Welsh, Blaine (USANV); gwoodberry Subject: RE: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) Kristin, the United States also does not oppose. Dave 20 From: Michael Freeman [mailto:mfreeman@earthjustice.org] Sent: Tuesday, July 05, 2011 12:57 PM To: 'Kristin McQueary'; Vance, Holly A. (USANV); Gehlert, David (ENRD); Welsh, Blaine (USANV); gwoodberry Subject: RE: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) 21 Kristin – we do not oppose. 22 From: Kristin McQueary [mailto:kmcqueary@elkocountynv.net] Sent: Tuesday, July 05, 2011 12:32 PM To: Vance, Holly A. (USANV); Gehlert, David (ENRD); Welsh, Blaine (USANV); gwoodberry; Michael Freeman Subject: Jarbidge South Canyon Road, --FW: Document Management Services (GENERATING) 19 23 24 Dear Counsel, 25 26 27 28 I would like to request a brief extension in which to file my reply to your responses. Our case management system is not generating documents at this time. See the emails below. At this time, we don’t know when it will be fixed. As my secretary will be gone on medical leave Thursday and Friday, I would like to request an extension until next Tuesday, July 12. Thank you, Kristin DA#01981 -5- 1 2 3 4 5 6 7 8 9 10 11 From: Karen Cracraft Sent: Tuesday, July 05, 2011 11:15 AM To: Chad Thompson; David Buchler; Jennifer Spencer; Kristin McQueary; Mark Mills; Mark Torvinen; Robert Lowe; Tyler Ingram; Darla Malotte; Georgeann Dalton; Georgia Jordan; JoAnne Lickly; Judith Dewitt; Julie Algerio; Kurri Darby; Liz Watson; Lorena Romero; Mercedes Woster; Tanya Yell Subject: FW: Document Management Services (GENERATING) FYI – Per Harry, we will NOT be generating until this is fixed. If you have a form that you need copied into the DADATA/FORMS file to use, let me know and I will do so. Also, I will put a copy of the subpoena shell and the disco receipt in DADATA/FORMS for your immediate use. Please add in ticklers to copy the work you do back into screen 12 of JALAN (or, in the case of the attorneys, let your caseworker know). Please save your work in DADATA/DEF (name it the DA number with a descriptive extension such as “12345.mtn” for a motion in DA file number 12345 or “12345.dsc” for a disco receipt. . Karen Cracraft Administrative Caseworker Elko County District Attorney's Office kcracraft@elkocountynv.net 775-738-3101 x250 12 13 14 15 16 17 From: Harry Jackson Sent: Tuesday, July 05, 2011 11:02 AM To: Karen Cracraft Subject: Document Management Services (GENERATING) 18 19 20 21 22 After upgrading the AS/400 to a newer version of Operating System – We are currently experiencing problems starting the older version of Document Management Services for the DA’s office. I have submitted a ticket to Sungard Public Sector to see if there is an easy way to resolve the problem. We’re hoping that this is merely a permissions issue (there have been a few of those already) and not an incompatibility between the DMS version and the Operating System. If the problem is the latter – we may be forced to upgrade the DA’s office to the current version of DMS in order to make it work. This would require a significant amount of archived documents that would need to be converted to a newer version of Microsoft Word. I requested a high level of urgency from Sungard in this matter as I know that this is a critical process for your 23 office. 24 Thanks, 25 26 27 28 Harry Berestful Jackson, Jr. Director of Information Technology Elko County 540 Court St. Elko, NV 89801 E-Mail: hjackson@elkocountynv.net Phone: 775-738-4038 Cell: 775-340-5557 DA#01981 -6-
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