John Doe I, et al., v. Jeremiah Mazo, et al.,

Filing 88

ORDER Granting 87 Stipulation to Vacate 6/29/2018 Hearing Date and Stay Case for 60 Days. Discovery due by 8/29/2018. Motions due by 9/28/2018. Proposed Joint Pretrial Order due by 10/29/2018. Signed by Magistrate Judge Peggy A. Leen on 6/13/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-00239-APG-PAL Document 87 Filed 06/12/18 Page 1 of 8
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Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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MARK E. FERRARIO
Nevada Bar No. 1625
[e-mail]
KARA B. HENDRICKS
Nevada Bar No. 7743
[e-mail]
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Fax:
[phone]
Counsel for Defendant
Clark County School District
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
JOHN and JANE DOE I, Guardians Ad Litem
for JOANN DOE I, a minor, individually and
on behalf of all those similarly situated, and
JOHN and JANE DOE II, Guardians Ad Litem
for JOANN DOE II, a minor, individually and
on behalf of all those similarly situated;
vs.

Case No. 2:16-cv-00239-APG-PAL

[PROPOSED] STIPULATION AND
ORDER TO VACATE JUNE 19, 2018
HEARING AND
STAY CASE FOR 60 DAYS

Plaintiffs,

JEREMIAH MAZO; CLARK COUNTY
SCHOOL DISTRICT; DOES 1 through 20;
DOE 1 through 20; ROE CORPORATIONS 1
through 20;
Defendants.

The parties are currently in settlement negotiations and have agreed to vacate the hearing

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scheduled for June 19, 2018 and delay the taking of the limited remaining depositions in this case to

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AND JANE DOE II, GUARDIANS AD LITEM FOR JOANN DOE II, A MINOR (collectively,

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help facilitate settlement discussions and reserve resources. In light of this agreement, Plaintiffs,

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“Plaintiffs”), Defendant CLARK COUNTY SCHOOL DISTRICT (“CCSD”), by and through their

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JOHN and JANE DOE I, GUARDIANS AD LITEM FOR JOANN DOE I, A MINOR AND JOHN

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respective counsel of record, hereby jointly submit this proposed stipulation extending certain case
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deadlines for the approval of the Court.

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Protective Order (Doc. No. 78) currently scheduled for June 19, 2018 at 10:00 a.m.

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are as follows:

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STIPULATION
The Parties hereby stipulate and agree to vacate the hearing regarding Plaintiffs’ Motion for

It is further stipulated and agreed pursuant to Local Rule 6-1, that the case be stayed for a
period of 60 days and the current discovery deadlines adjusted accordingly. The current deadlines

Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Discovery Cut-Off Date:
Dispositive Motions:

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I.

July 30, 2018

Proposed Joint Pretrial Order:

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June 30, 2018

August 29, 2018 or 30 days after
the Court rules on any
dispositive motions.

Background

This case was filed on February 5, 2016, alleging abuse of students by a former CCSD
teacher, Jeremiah Mazo, and bringing claims under Title IX against CCSD and state tort claims
against all defendants. (Doc. 1). Plaintiffs filed a First Amended Class Action Complaint on March
1, 2017. (Doc. 39). CCSD filed its Answer to the First Amended Class Action Complaint on March
16, 2017, and asserted cross-claims against Defendant Mr. Mazo. (Doc. 43). Mr. Mazo filed an
Answer to the Plaintiffs’ First Amended Class Action Complaint on June 2, 2017 and his answer to
CCSD’s Cross-Claims on July 6, 2017 (Doc. Nos. 61, 67).
II.

Discovery Completed

Plaintiffs have served Defendant Clark County School District with the following
discovery to date:
1.

Plaintiffs’ Early Case Conference List of Documents and Witnesses Pursuant to
FRCP 26(F) served 10/10/2016;

2.

Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and
Jane Doe II, Guardians ad Litem for Joann Doe II’s First set of Request of
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Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Production of Documents served 10/27/16;
3.

Witnesses Pursuant to FRCP 26(F) served 12/14/2016;
4.

5.

6.

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served 12/14/2016;

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13.

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Plaintiff John Doe II as Guardian ad Litem for Joann Doe II’s Responses to Clark
County School District’s First set of Interrogatories served 12/14/2016;

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Plaintiff Joann Doe II’s Responses to Clark County School District’s First set of
Interrogatories served 12/14/2016;

12.

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Plaintiff Jane Doe II as Guardian ad Litem for Joann Doe II’s Responses to Clark
County School District’s First set of Interrogatories served 12/14/2016;

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Plaintiffs John and Jane Doe I as Guardians ad Litem for Joann Doe I’s Responses to
Clark County School District’s First set of Request for Production of Documents

11.

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Plaintiff John Doe I as Guardian ad Litem for Joann Doe I’s Responses to Clark
County School District’s First set of Interrogatories served 12/14/2016;

8.

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Plaintiff Joann Doe I’s Responses to Clark County School District’s First set of
Interrogatories served 12/14/2016;

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Plaintiff Jane Doe I as Guardian ad Litem for Joann Doe I’s Responses to Clark
County School District’s First set of Interrogatories served 12/14/2016;

7.

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Plaintiffs’ First Supplement to Early Case Conference List of Documents and

Plaintiffs John and Jane Doe II as Guardians ad Litem for Joann Doe II’s Responses
to Clark County School District’s First set of Request for Production of Documents
served 12/14/2016;
Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and
Jane Doe II, Guardians ad Litem for Joann Doe II’s Second set of Requests for
Production of Documents served 01/18/2017;
Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of
Requests for Admission served 01/18/2017;

14.

Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of
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Interrogatories served 01/18/2017;
15.

Interrogatories served 01/18/2017;
16.

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Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of
Requests for Admission served 01/18/2017;

17.

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Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of

Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and
Jane Doe II, Guardians ad Litem for Joann Doe II’s Third set of Requests for
Production of Documents served 01/20/2017;
Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s Second set of
Interrogatories served 01/23/2017;

19.

Plaintiffs’ Second Supplement to Early Case Conference List of Documents and
Witnesses Pursuant to FRCP 26(F) served 02/10/17;

20.

Plaintiff Joann Doe II’s Supplemental Responses to CCSD’s First set of
Interrogatories served on 03/01/17;

21.

Plaintiff Joann Doe I’s Supplemental Responses to CCSD’s First set of
Interrogatories served on 03/01/17;

22.

Plaintiffs’ Third Supplement to Early Case Conference List of Documents and
Witnesses Pursuant to FRCP 26(F) served 05/31/17;

23.

Plaintiffs’ Fourth Supplement to Early Case Conference List of Documents and
Witnesses Pursuant to FRCP 26(F) served 07/07/17;

24.

Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Third Set of
Interrogatories to CCSD served 07/11/17;

25.

Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Fourth Set of
Interrogatories to CCSD served 08/22/17;

26.

Plaintiffs’ Fifth Supplement to Early Case Conference List of Documents and
Witnesses Pursuant to FRCP 26(F) served 10/11/17;

27.

Plaintiffs’ Expert Designation Pursuant to FRCP 26(A)(2) served 10/13/17.
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Defendant Clark County School District has served Plaintiffs with the following
discovery to date:

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1.

CCSD’s Initial Disclosures served 10/05/2016;

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2.

CCSD’s First set of Interrogatories to Plaintiff Jane Doe I, as Guardian ad Litem for

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3.

CCSD’s First set of Interrogatories to Plaintiff Joann Doe I served 11/14/2016;

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4.

CCSD’s First set of Interrogatories to Plaintiff John Doe I, as Guardian ad Litem for

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5.

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Joann Doe I served 11/14/2016;

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3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Joann Doe I served 11/14/2016;

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CCSD’s First set of Requests for Production of Documents to Plaintiffs John and
Jane Doe I, as Guardians ad Litem for Joann Doe I served 11/14/2016;

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6.

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CCSD’s First set of Interrogatories to Plaintiff Jane Doe II, as Guardian ad Litem for
Joann Doe II served 11/14/2016;

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7.
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CCSD’s First set of Interrogatories to Plaintiff Joann Doe II served 11/14/2016;
CCSD’s First set of Interrogatories to Plaintiff John Doe II, as Guardian ad Litem for
Joann Doe II served 11/14/2016;

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9.

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CCSD’s First set of Requests for Production of Documents to Plaintiffs John and
Jane Doe II, as Guardians ad Litem for Joann Doe II served 11/14/2016;

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10.

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CCSD’s First Supplemental Disclosures served 12/01/2016;

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12.

CCSD’s Second Supplemental Disclosures served 02/17/17;

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13.

CCSD’s Third Supplemental Disclosures served 02/24/17;

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14.

CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a

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15.

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to the Clark County School District served 12/01/2016;

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CCSD’s Responses to Plaintiffs’ First set of Requests for Production of Documents

Minor’s First Set of Requests for Admission to CCSD served 02/24/17;
CCSD’s Responses to Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a
Minor’s First Set of Requests for Admission to CCSD served 02/24/17;
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Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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16.

CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a
Minor’s First set of Interrogatories to CCSD served 02/27/17;

17.

CCSD’s Responses to Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a
Minor’s First set of Interrogatories to CCSD served 02/27/17;

18.

CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a
Minor’s Second set of Interrogatories to CCSD served 03/10/17;

19.

CCSD’s Fourth Supplemental Disclosures Pursuant to FRCP 26(a)(1) and Pursuant
to March 6, 2017 Order served 04/05/17;

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20.

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CCSD’s Fourth Supplemental Disclosures served 08/21/17;

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22.

CCSD’s Responses to Plaintiff Jon Doe I, as Guardian ad Litem for Joann Doe I, a

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CCSD’s Sixth Supplemental Disclosures served 09/01/2017;

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CCSD’s Seventh Supplemental Disclosures served 10/13/17;

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CCSD’s Expert Witness Disclosures served 10/13/17.

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CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a
Minor’s Third set of Interrogatories to CCSD served 07/24/17;

Minor’s Fourth set of Interrogatories to CCSD served 09/21/17;

The following depositions have been completed to date:

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1.

Ulandra Barnett

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2.

Ivy Burns

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3.

Sylvia Glass

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4.

Jennifer Mattiello

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5.

Nestor Mattiello

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Jon Okazaki

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Julia Pettit

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Kristopher Pettit

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Christine Prosen

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10.

Darrin Puana
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11.

Billie Rayford

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Joann Lippert

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III.

Discovery That Remains to be Completed

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1.

Depositions of Plaintiffs Joann Doe I and Joann Doe II; 1 and

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2.

Certain Expert Depositions 2

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IV.

Basis for Extension

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The parties request this stay and extension of discovery to allow the depositions of Joann

Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Doe I, Joann Doe II (subject to Motion for Protective Order), and certain of the parties’ expert

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witnesses to take place should settlement negotiations come to an impasse. The parties have

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be vacated and request an extension to allow for the foregoing outstanding discovery to be

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Based on the foregoing, the parties jointly seek a modification of the current deadlines as

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diligently engaged in discovery and want to avoid incurring any additional expense at this time.

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completed 60 days from the current deadlines as detailed below.

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follows:

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Accordingly, the parties request a 60 day stay of this matter, request that the June 19, 2018 hearing

V.

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2.

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July 30, 2018
August 29, 2018 or 30 days
after the Court rules on any
dispositive motions.

Proposed Deadlines:
Discovery Cut-Off Date:

August 29, 2018

Dispositive Motions:

September 28, 2018

Proposed Joint Pretrial Order:

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June 30, 2018

Proposed Joint Pretrial Order:

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Current Deadlines:
Discovery Cut-Off Date:
Dispositive Motions:

1.

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Proposed Modification

October 29, 2018 or 30 days

The ability for such deposition to go forward is the subject of Plaintiff’s Motion for Protective Order (Doc. No. 78).
Defendants have taken the deposition of Plaintiffs’ expert Joann Lippert. The parties scheduled the depositions of
experts Terrence Clauretie, Edward Dragan, Peter Loehr and Brett Sokolow for the latter part of June, but agree to
continue such depositions to allow for settlement discussions.

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Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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after the Court rules on any
dispositive motions.
3.

This request is made in good faith and not for the purposes of delay.

IT IS SO STIPULATED.
Dated this 12th day of June, 2018.

Dated this 12th day of June 2018.

GREENBERG TRAURIG, LLP

EGLET PRINCE

/s/ Kara B. Hendricks
MARK E. FERRARIO, ESQ. (NV BAR 1625)
KARA B. HENDRICKS, ESQ. (NV BAR 7743)
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, Nevada 89169
Attorneys for Defendant Clark County
School District

/s/ Artemus W. Ham
ROBERT T. EGLET, ESQ. (NV BAR 3402)
ARTEMUS W. HAM, ESQ. (NV BAR 7001)
AARON D. FORD, ESQ. (NV BAR 7704)
400 S. 7th Street, 4th Floor
Las Vegas, Nevada 89101
Attorneys for Plaintiffs

-andHALL JAFFE & CLAYTON, LLP
STEVEN T. JAFFE, ESQ. (NV BAR 7035)
7425 Peak Drive
Las Vegas, Nevada 89128
Attorneys for Defendant Clark County
School District

ORDER
IT IS HEREBY ORDERED.
DATED this 13th day of June, 2018.

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____________________________________________
UNITED STATES MAGISTRATE JUDGE

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