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KAREN A. CONNOLLYNevada Bar No. 4240 KAREN A. CONNOLLY, LTD.6600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89146Telephone: (702) 678-6700Facsimile: (702) 678-6767E-Mail: [email protected] for RESPONDENT
IN THE SUPREME COURT OF THE STATE OF NEVADA
LAUREN BETH BIERSTEDT,N/K/A LAUREN ANDERSON,
Appellant,
vs.
JOEL BIERSTEDT
Respondent.
Supreme Court No. 82858District Ct. Case No. D-11-440918-D
RESPONDENT’S ANSWER TOAPPELLANT’S PETITION TO
REINSTATE APPEAL AND STAYREMITTITUR
Karen A. ConnollyKAREN A. CONNOLLY, LTD.6600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89146Telephone: (702) 678-6700Attorney for Respondent
Alex GhibaudoALEX B. GHIBAUDO, P.C.197 E. Calfornia Avenue, Ste 250Las Vegas, NV 89104Telephone (702) 462-5888Attorney for Appellant
Electronically FiledAug 23 2021 10:19 a.m.Elizabeth A. BrownClerk of Supreme Court
Docket 82858 Document 2021-24438
NRAP 26.1 DISCLOSURE
The undersigned counsel of record certifies that the following are persons and
entities as described in NRAP 26.1(a), and must be disclosed. These representations
are made in order that the judges of this court may evaluate possible disqualification
or recusal.
1. Attorney of Record for Respondent: Karen A. Connolly
2. Publicly-held Companies Associated: None
3. Law Firm(s) Appearing in the Court(s) Below: Karen A. Connolly, Ltd.
DATED this 23rd day of August, 2021.
KAREN A. CONNOLLY, LTD.
/s/ Karen A. Connolly KAREN A. CONNOLLYNevada Bar No. 42406600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89146Attorney for Respondent
MEMORANDUM OF POINTS AND AUTHORITIES
As directed by this court on August 10, 2021, Respondent JOEL BIERSTEDT,
presents this Answer to Appellant’s Petition to Reinstate Appeal and Stay Remittitur
filed on July 29, 2021. That same date, an Order Dismissing Appeal and Referring
Counsel to the State Bar of Nevada for Investigation was filed by this Court.
Thereafter, Appellant filed a Motion to Reconsider Dismissal of Action and Motion
To Extend Time to Comply With the Court’s July 8, 2021 Order which was rejected
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by the Court.
On August 15, 2021, a Stipulation and Order was entered in the district court
case D-11-440918-D, resolving the underlying issue on appeal: an award of attorney
fees to Respondent in this district court. A copy is attached hereto as Exhibit A. The
terms of the Stipulation require Appellant to withdraw her petition by August 20,
2021. Accordingly, Respondent takes no position.
Dated: August 23rd, 2021
/s/ Karen A. Connolly KAREN A. CONNOLLYNevada Bar No. 4240KAREN A. CONNOLLY, LTD.6600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89146Tel: (702) 678-6700
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AFFIRMATION
The undersigned does hereby affirm that pursuant to NRS 239B.030, the
preceding document does not contain the social security number of any person.
Dated: August 23rd, 2021.
/s/ Karen A. Connolly KAREN A. CONNOLLYNevada Bar No. 4240KAREN A. CONNOLLY, LTD.6600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89146Tel: (702) 678-6700
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I am an employee of KAREN A. CONNOLLY,
LTD., and on the 23rd day of August, 2021, I served a true and correct copy of the
above and foregoing Respondent’s Answer to Appellant’s Petition to Reinstate
Appeal and Stay Remittur pursuant to NRAP 25 by the method or methods indicated
below:
: by electronic service via eFlex:
Alex B. Ghibaudo, Esq.
Attorney for Appellant
/s/ Eric Siegler An Employee of KAREN A. CONNOLLY, LTD.
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EXHIBIT A
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. Con
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ile:
(702
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8-67
67SAOKaren A. ConnollyNevada Bar No. 4240 KAREN A. CONNOLLY, LTD.6600 W. Charleston Blvd., Ste. 124Las Vegas, NV 89136Telephone: (702) 678-6700Facsimile: (702) 678-6767E-Mail: [email protected] for Plaintiff
DISTRICT COURT, FAMILY DIVISIONCLARK COUNTY, NEVADA
* * * * *
JOEL BIERSTEDT,
Plaintiff,
vs.
LAUREN BETH BIERSTEDT,
Defendant.
CASE NO.: D-11-440918-DDEPT. NO.: U
STIPULATION AND ORDER
WHEREAS, pursuant to orders of the court on March 1, 2021 and March 23,
2021, and subsequent judgments dated April 5, 2021, Defendant LAUREN
ANDERSON, hereinafter “LAUREN” owes Plaintiff JOEL BIERSTEDT, hereinafter
“JOEL” attorney fees in the amount of $6,609.00;
WHEREAS JOEL owed child support arrears to LAUREN in the amount of
$5,945.52 as of April 22, 2021 and having made additional payments towards arrears
of $400.00 since then, the balance due and owing is $5,545.52;
WHEREAS ON April 26, 2021, LAUREN filed a Notice of Appeal identified
as Supreme Court case No. 82858 relative to the attorney fee awards which was
dismissed on July 29, 2021 and LAUREN having filed a Petition for Reconsideration
in case 82858 on July 29, 2021;
The parties agree as follows
IT IS HEREBY STIPULATED that in consideration of this agreement, child
support arrears in case R-14-185305-R have been satisfied. A copy of this order will
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Electronically Filed08/15/2021 12:01 PM
Case Number: D-11-440918-D
ELECTRONICALLY SERVED8/15/2021 12:01 PM
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CSERV
DISTRICT COURTCLARK COUNTY, NEVADA
CASE NO: D-11-440918-DJoel Bierstedt, Plaintiff
vs.
Lauren Beth Bierstedt, Defendant.
DEPT. NO. Department U
AUTOMATED CERTIFICATE OF SERVICE
This automated certificate of service was generated by the Eighth Judicial District Court. The foregoing Stipulation and Order was served via the court’s electronic eFile system to all recipients registered for e-Service on the above entitled case as listed below:
Service Date: 8/15/2021
Karen Connolly [email protected]
Legal Assistant [email protected]
Ericka Calderon [email protected]
Alex Ghibaudo [email protected]
Alex Ghibaudo [email protected]
Michancy Cramer [email protected]