Rodriguez-Malfavon v. Clark County School District et al

Filing 74

ORDER Granting 73 Stipulation to Exclude Certain Evidence at Trial. Signed by Judge Andrew P. Gordon on 8/22/16. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:12-cv-01673-APG-PAL Document 73 Filed 08/19/16 Page 1 of 2

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BRUCE C. YOUNG, ESQ., Bar #5560
ETHAN D. THOMAS, ESQ., Bar #12874
LITTLER MENDELSON, P.C.
3960 Howard Hughes Parkway, Suite 300
Las Vegas, NV 89169-5937
Telephone:
702.862.8800
Fax No.:
702.862.8811
Email: [e-mail]
[e-mail]
Attorneys for Defendant
CLARK COUNTY SCHOOL DISTRICT

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ELENA RODRIGUEZ-MALFAVON,

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Plaintiff,

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vs.

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CLARK COUNTY SCHOOL DISTRICT,

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

STIPULATION AND ORDER TO
EXCLUDE CERTAIN EVIDENCE AT
TRIAL

Defendant.

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Plaintiff ELENA RODRIGUEZ-MALFAVON (“Plaintiff”) and Defendant CLARK

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COUNTY SCHOOL DISTRICT (“Defendant”), by and through their respective counsel of record,

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hereby stipulate and agree to exclude certain evidence at trial pursuant to Local Rule 16-3.

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Local Rule 16-3 now requires the parties to participate in the meet-and-confer process prior

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to filing motions in limine before the Court. LR 16-3. The parties recently engaged in meet-and-

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confer efforts regarding four specific issues Defendant proposed should be excluded from trial.

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Having reached an agreement on those issues, the parties hereby stipulate to exclude the following

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evidence from the upcoming trial which is limited to Plaintiff’s Title VII retaliation claim:

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

1. Any evidence or references to other past instances of alleged discrimination or retaliation of
other CCSD employees by Bramby Tollen, Edward Goldman, or any other CCSD employee.
2. Any evidence or references to the circumstances surrounding why Bramby Tollen’s
employment with CCSD ended in 2014.

Case 2:12-cv-01673-APG-PAL Document 73 Filed 08/19/16 Page 2 of 2

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3. Any evidence or references to alleged medical damages or injuries Plaintiff claims to have

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suffered as a result of the alleged Title VII retaliation.
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Any evidence or references to indirect financial damages Plaintiff claims to have suffered

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because of her demotion in 2011, including but not limited to the need for Plaintiff to

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refinance her cars or home.

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The parties file the instant stipulation to memorialize these agreements and ask that the Court

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herby Order that evidence or references to these issues be excluded from trial in this matter.

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Dated: August 19, 2016

Dated: August 19, 2016

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Respectfully submitted,

Respectfully submitted,

/s/ Richard Segerblom
RICHARD SEGERBLOM, ESQ.

/s/ Ethan D. Thomas
BRUCE C. YOUNG, ESQ.
ETHAN D. THOMAS, ESQ.
LITTLER MENDELSON, P.C.

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Attorney for Plaintiff
ELENA RODRIGUEZ-MALFAVON

Attorneys for Defendant
CLARK COUNTY SCHOOL DISTRICT

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ORDER

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IT IS SO ORDERED.

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______________________________
Dated: _____________________, 2016.
UNITED STATES DISTRICT JUDGE
Dated: August 22, 2016.

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_______________________________________
UNITED STATES DISTRICT COURT JUDGE

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

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