Leff et al v. Clark County School District

Filing 31

ORDER Granting 30 Stipulation for Extension of Time (First Request). Signed by Magistrate Judge George Foley, Jr on 4/3/17. (Copies have been distributed pursuant to the NEF - MR)

1 CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL
2 S. SCOTT GREENBERG, ESQ.
Nevada Bar No. 4622
3 5100 W. Sahara Ave.
Las Vegas, Nevada 89146
4 [phone]
Attorneys for Defendant CCSD
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JILL LEFF, et al,
Plaintiff,

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v.

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CLARK COUNTY SCHOOL
DISTRICT, a county school
district,

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CASE NO.: 2:15-cv-01155-RFB-GWF

STIPULATION AND ORDER TO CONDUCT
DEPOSITIONS AFTER DISCOVERY
DEADLINE
(First Request)

Defendant.

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COME NOW the parties, by and through their counsel of record,

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and hereby stipulate and agree that the parties may take depositions

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of Plaintiffs not deposed during the discovery period for the

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purpose of damage issues up to sixty (60) days following a ruling

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on dispositive motions.

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depositions beyond the discovery deadline.

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intended for any reason of delay but to allow the litigation to

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proceed in a cost-effective manner consistent with Fed.R.Civ.P. 1

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which provides the rules of civil procedure “should be construed,

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administered, and employed by the court and the parties to secure

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/ / /

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/ / /

This is the first request to allow
This request is not

Case 2:15-cv-01155-RFB-GWF Document 30 Filed 03/31/17 Page 2 of 3

1 the just, speedy, and inexpensive determination of every action and
2 proceeding.”

The parties agree this stipulation will not be used

3 as a defense or objection to injunctive relief Plaintiffs may seek
4 nor is this stipulation a waiver of any applicable defense or
5 objection should injunctive relief be entered by the court.
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The discovery deadline is April 4, 2017.

7 motion deadline is May 4, 2017.

The dispositive

The parties will be filing motions

8 for summary judgment following the close of discovery.
9 fifteen (15) individual Plaintiffs.

There are

While the legal issues are

10 common to the Plaintiffs, damage issues will be individualized to
11 the various Plaintiffs.

Damage issues will not be relevant to

12 dispositive motions; therefore, the parties wish to have a ruling
13 on dispositive motions before expending the time and expense on
14 depositions for damage issues and which may be avoided depending on
15 the Court’s dispositive motions ruling. Therefore, the parties have
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conduct Plaintiffs’ depositions, for Plaintiffs not

17 already deposed, regarding damage issues only not later than sixty
18 (60) days after a ruling on dispositive motions should any claims
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Case 2:15-cv-01155-RFB-GWF Document 30 Filed 03/31/17 Page 3 of 3

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Therefore, the parties respectfully request that they be

2 allowed to conduct depositions of Plaintiffs not already deposed as
3 to damage issues only no later than sixty (60) days following a
4 ruling on dispositive motions.
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Dated this 29th day of March, 2017.

6 CLARK COUNTY SCHOOL DISTRICT
Office of the General Counsel
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DYER, LAWRENCE, FLAHERTY,
DONALDSON & PRUNTY

8 By: /s/ S. Scott Greenberg
S. SCOTT GREENBERG
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Nevada Bar No. 4622
5100 W. Sahara Ave.
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Las Vegas, Nevada 89146
[phone]
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Attorneys for Defendant
CCSD
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By: /s/ Thomas J. Donaldson
THOMAS J. DONALDSON
Nevada Bar No. 5282
2805 Mountain Street
Carson City, NV 89703
[phone]
Attorneys for Plaintiffs

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IT IS SO ORDERED:
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Dated: April 3, 2017
U.S. Magistrate Judge

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