Case 2:14-cv-00441-REB Document 21 Filed 01/28/15 Page 1 of 3

Kirtlan G. Naylor
[ISB No. 3569]
Jacob H. Naylor
[ISB No. 8474]
Landon S. Brown
[ISB No. 9023]
NAYLOR & HALES, P.C.
Attorneys at Law
950 W. Bannock Street, Ste. 610
Boise, Idaho 83702
Telephone No. (208) 383-9511
Facsimile No. (208) 383-9516
Email: kirt@naylorhales.com; jake@naylorhales.com; landon@naylorhales.com
Attorneys for Defendant

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF IDAHO
DONALD KNAPP; EVELYN KNAPP;
HITCHING POST WEDDINGS, LLC,

Case No. 2:14-CV-00441-REB

Plaintiffs,
vs.

THIRD JOINT PETITION FOR STAY

OF PROCEEDINGS

CITY OF COEUR DALENE,

Defendant.

Plaintiffs and Defendant, by and through undersigned counsel, jointly petition this
Court for an Order staying proceedings for additional time until March 10, 2015, at which time a
responsive pleading will be filed by the Defendant, if necessary. This request is based on the fact
that undersigned counsel have had the opportunity to consult regarding this matter and
undersigned counsel is authorized to represent to the Court that the parties are close to resolving
this case short of litigation, but need this additional time requested.

THIRD JOINT PETITION FOR STAY OF PROCEEDINGS - 1

Case 2:14-cv-00441-REB Document 21 Filed 01/28/15 Page 2 of 3

The parties previously requested a stay twice (Dkt Nos. 15 and 19), which were
granted by this Court (Dkt Nos. 16 and 20). The parties continue to discuss matters relating to
the possible resolution of the case short of litigation, and request the addition time. This request
is not made to delay, but is made in good faith by the parties. The parties reasonably believe this
request will save judicial resources should the parties resolve the matter.
Accordingly, the parties hereby jointly request a stay of the current proceedings
until March 10, 2015.
DATED this 28th day of January, 2015.
NAYLOR & HALES, P.C.

By: /s/ Kirtlan G. Naylor. Naylor, Of the Firm

Attorneys for Defendant City of Coeur
dAlene

ALLIANCE DEFENDING FREEDOM

By: /s/ Jeremy Tedesco

Attorneys for Plaintiffs

THIRD JOINT PETITION FOR STAY OF PROCEEDINGS - 2

Case 2:14-cv-00441-REB Document 21 Filed 01/28/15 Page 3 of 3

CERTIFICATE OF SERVICE
I hereby certify that on the 28th day of January, 2015, I electronically filed the
foregoing with the Clerk of the Court using the CM/ECF system which sent a Notice of
Electronic Filing to the following person(s):

David A. Cortman; dcortman@alliancedefendingfreedom.org

Kevin H. Theriot; ktheriot@alliancedefendingfreedom.org
Rory T. Gray; rgray@alliancedefendingfreedom.org
Jeremy D. Tedesco; jtedesco@alliancefendingfreedom.org
Jonathan A. Scruggs; jscruggs@alliancefendingfreedom.org
Virginia McNulty Robinson vrobinson@robinsonlaw-pllc.com

Attorneys for Plaintiffs

/s/ Kirtlan G. Naylor

9293_12 Third Petition for Stay of Proceedings.w pd

THIRD JOINT PETITION FOR STAY OF PROCEEDINGS - 3