Rodriguez-Malfavon v. Clark County School District et al

Filing 43

ORDER granting 42 Stipulation extending the time to file a response to 39 MOTION for Summary Judgment to July 1, 2015. Signed by Judge Andrew P. Gordon on 3/3/2015. (Copies have been distributed pursuant to the NEF - DKJ)

Case 2:12-cv-01673-APG-PAL Document 42 Filed 03/03/15 Page 1 of 3

1
2
3
4

RICHARD SEGERBLOM, ESQ., Bar # 1010
700 South Third Street
Las Vegas, Nevada 89101
Telephone: [phone]
Fax No.:
702.385.2909
Attorney for Plaintiff
ELENA RODRIGUEZ-MALFAVON

5
6
7
8

PATRICK H. HICKS, ESQ., Bar # 4632
ETHAN D. THOMAS, ESQ., Bar # 12874
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169-5937
Telephone: [phone]
Fax No.:
702.862.8811

9
10
11
12
13
14

JAMIE CHU, ESQ., Bar # 10546
LITTLER MENDELSON, P.C.
2050 Main Street, Suite 900
Irvine, CA 92614
Telephone:
949.705.3000
Fax No.:
949.724.1201
Attorneys for Defendants
CLARK COUNTY SCHOOL DISTRICT,
EDWARD GOLDMAN and ANITA WILBUR

15
UNITED STATES DISTRICT COURT
16
DISTRICT OF NEVADA
17
18
ELENA RODRIGUEZ-MALFAVON,

CASE NO. 2:12-CV-01673-APG-PAL

19
Plaintiff,
20
vs.
21
22

CLARK COUNTY SCHOOL DISTRICT,
EDWARD GOLDMAN and ANITA
WILBUR,

STIPULATION AND ORDER TO EXTEND
TIME FOR PLAINTIFF TO FILE AN
OPPOSITION TO DEFENDANTS’
MOTION FOR SUMMARY JUDGMENT
[SECOND REQUEST]

23
Defendant.
24
25

In compliance with Local Rules 6-1 and 26-4, Defendants CLARK COUNTY SCHOOL

26

DISTRICT, EDWARD GOLDMAN and ANITA WILBUR (collectively referred to as

27

“Defendants”) and Plaintiff ELENA RODRIGUEZ-MALFAVON (“Plaintiff”), by and through

28

their respective counsel of record, hereby stipulate and agree to extend the time for Plaintiff to file

LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

Case 2:12-cv-01673-APG-PAL Document 42 Filed 03/03/15 Page 2 of 3

1
2
3
4
5

an opposition to Defendants’ Motion for Summary Judgment (Doc #39) filed January 7, 2015 by
120-days. The initial deadline for filing the opposition was February 2, 2015. Pursuant to the
parties’ first stipulation to extend the deadline for Plaintiff to file an opposition to Defendants’
Motion for Summary Judgment, the deadline was extended to March 4, 2015. The new deadline
for Plaintiff’s opposition will be, up to and including, July 1, 2015.

6
7
8
9
10

This stipulation is submitted as an extension is necessary because Plaintiff’s counsel is
continuing to assist with a family member’s medical condition which requires regular treatment at
the Mayo Clinic in Phoenix, Arizona. Additionally, from now until June 1, 2015, Plaintiff’s
counsel will be spending his weekdays and some weekends serving as a State Senator in the
Nevada legislature in Carson City, Nevada. To that end, NRS 1.310(2) and (3) provide that:

11
2. If an attorney for a party to any action or proceeding in any
court or before any administrative body, who was actually employed
before the commencement of any legislative session, is a member of
the Legislature of the State of Nevada, or is President of the Senate,
that fact is sufficient cause for the adjournment or continuance of the
action or proceeding, including, without limitation, any discovery or
other pretrial or posttrial matter involved in the action or proceeding,
for the duration of any legislative session.

12
13
14
15
16

3. The adjournment or continuance provided for in subsections 1
and 2 must be granted without the imposition of terms.

17
18

Although this Court is obviously not bound by Nevada law, it can certainly look to guidance set

19

forth in Nevada law if it is relevant.

20
21
22

///
///

23
24

///

25
26
27
28
LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

2.

Case 2:12-cv-01673-APG-PAL Document 42 Filed 03/03/15 Page 3 of 3

1

The parties agree and represent to the Court that this request is made in good faith and not for

2

the purposes of delay. They also agree that given the length of this proposed continuance no further

3

extensions will be granted to the Plaintiff and/or her attorney.

4
5

Dated: March 3, 2015

Dated: March 3, 2015

6

Respectfully submitted,

Respectfully submitted,

/s/ Richard Segerblom
RICHARD SEGERBLOM, ESQ.

/s/ Ethan D. Thomas
PATRICK H. HICKS, ESQ.
JAMIE CHU, ESQ.
ETHAN D. THOMAS, ESQ.
LITTLER MENDELSON, P.C.

7
8
9
10

Attorney for Plaintiff
ELENA RODRIGUEZ-MALFAVON

11

Attorneys for Defendants
CLARK COUNTY SCHOOL DISTRICT,
EDWARD GOLDMAN and ANITA WILBUR

12
13

ORDER

14
15

IT IS SO ORDERED.

16

March 3
Dated: _____________________, 2015.

17
18
_______________________________________
____________________________
UNITED STATES DISTRICT COURT JUDGE

19
20
21

Firmwide:132016249.1 026133.1015

22
23
24
25
26
27
28
LITTLER MENDELSON, P.C.
ATTORNEYS AT LAW
3960 Howard Hughes Parkway
Suite 300
Las Vegas, NV 89169-5937
702.862.8800

3.