IN UNITED STATES COURT OF APPEALS
Brian P. Carr
APPEAL FROM AN ORDER OF THE UNITED STATES DISTRICT COURT
BRIEF OF APPELLEES Harris, Nichols, B. Johnson, Eiesland, Melnick, Hagensen, Osler
Bernard F. Veljacic
TABLE OF CONTENTS
|I.||ADOPTION BY REFERENCE||1|
|III.||STATEMENT OF RELATED CASES||1|
|IV.||CERTIFICATE OF COMPLIANCE||1|
TABLE OF AUTHORITIESPlease see Co-Appellee's brief.
I. ADOPTION BY REFERENCE.
In the interests of judicial economy and to avoid unnecessary duplication, the Clark County Appellees, pursuant to Fed. R. App. P. 28(i), hereby adopt by reference the brief of the State Appellees, authored by John Nicholson, including the Jurisdictional Statement, Counterstatement of the Issues, Statement of the Case, Statement of Facts, Statement of Standard of Review.
The Clark County Appellees also adopt by reference the applicable portions of Mr. Nicholson's argument, specifically sections B.1 (Rooker Feldman Doctrine), B.2 (Res Judicata), and B.3 (Absolute Judicial Immunity).
Based on the adopted argument and authority, Clark County Appellees submit the District Court properly determined plaintiff-appellant's claims on summary judgment. Clark County Appellees respectfully request that the determination and judgment of the trial court be affirmed in all respects.
III. STATEMENT OF RELATED CASES
There are no related cases pending before the Ninth Circuit Court of Appeals.
IV. CERTIFICATEOF COMPLIANCE
The Clark County Appellees' brief is double spaced (except for indented quotes and footnotes) and is typed in a proportional font. The point size is 14 and the word count is 398.
DATED this the 28 day of January, 2008.
Deputy Prosecuting Attorney
Clark County Prosecuting Attorney
Of Attorneys for Clark County Appellees Harris, Nichols, B. Johnson, Eiesland, Melnick, Hagensen, Osler