Rice v. Clark County School District

Filing 45

ORDER Granting 41 Stipulation for Extension of Time (First Request) re 34 MOTION Re-Open Limited Discovery. Defendant's Responses due by 6/14/2017. Signed by Magistrate Judge Peggy A. Leen on 6/2/2017. (Copies have been distributed pursuant to the NEF - SLD) Modified to link to proper docket entry on 6/2/2017 (SLD).

Case 2:16-cv-01709-JCM-PAL Document 41 Filed 06/01/17 Page 1 of 3

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]
Email: [e-mail]
5 Attorney for Defendant,
CLARK COUNTY SCHOOL DISTRICT
6
UNITED STATES DISTRICT COURT
7
DISTRICT OF NEVADA
8
CASE NO. 2:16-cv-01709-JCM-PAL
9 LESLIE RICE,
STIPULATION TO EXTEND TIME FOR
DEFENDANT
TO
RESPOND
TO
PLAINTIFF’S MOTION TO RE-OPEN
DISCOVERY

Plaintiff,

10
11

v.

12

CLARK COUNTY SCHOOL DISTRICT,
(First Request)
Defendant.

13
14

COME NOW, the parties, by and through their attorneys of

15 record, and hereby stipulate and agree to allow Defendant up to and
16 including Wednesday, June 14, 2017, to respond to Plaintiff’s Motion
17 to Re-Open Discovery (Docket No. 34) filed May 17, 2017.

The

18 response is currently due May 31, 2017 and this is the first request
19 to extend time for the response.
20

On May 26th the parties filed a stipulation to extend the time

st
th
21 for Defendant’s response from May 31 to June 9 .

Docket No. 38.

22 At the time filing that stipulation, defense counsel forgot that the
th
23 District’s legal office is moving on June 9 .

Defense counsel must

th
and the move,
24 have his office packed by the end of June 8
th
25 including computers, is to take place on June 9 and through the

26 weekend.

This

request

to

extend

the

time

to

the

following

th
th
27 Wednesday, June 14 ,is to ensure with the office move of June 9

28 that defense counsel will be able to complete the opposition.

With

the filing of this stipulation, Docket No. 38 will be withdrawn.

Case 2:16-cv-01709-JCM-PAL Document 41 Filed 06/01/17 Page 2 of 3

1 The following is the basis for the extension request set forth in
2 the parties previous stipulation in addition to the office move
3 discussed above.
4

The dispositive motion deadline is June 9, 2017.

5 31.

In addition to the motion deadline in this matter and current

Docket No.

6 motions Plaintiff recently filed that require responses, defense
7 counsel also has had summary judgment motions due in two (2) other
8 federal cases and a response to an OSHA employee retaliation
9 complaint and has an employee dismissal arbitration scheduled for
10 June 6th.

This request for additional time is being made in good

11 faith based upon defense counsel’s schedule as noted herein (and May
12 29th is a holiday).

Defendant will be filing a motion for summary

13 judgment and this request will have Defendant’s response to the
14 pending motion due the same time as the motion deadline as the
15 parties are filing stipulations with regard to the motion deadline
16 and other pending Plaintiff’s motion to amend complaint so all will
17 be due June 14th.
18

Therefore, for the foregoing reasons, it is respectfully

19 requested that the time for Defendant’s response to Docket No. 34
20 / / /
21 / / /
22 / / /
23 / / /
24 / / /
25 / / /
26 / / /
27 / / /
28 / / /
-2-

Case 2:16-cv-01709-JCM-PAL Document 41 Filed 06/01/17 Page 3 of 3

1 be extended up to and including June 14, 2017, given defense
2 counsel’s schedule and office move scheduled for June 9th described
3 above.
DATED this 31st day of May, 2017.

4
5

6 CLARK COUNTY SCHOOL DISTRICT
Office of the General Counsel
7
8 By:
9
10
11

DICKINSON WRIGHT PLLC

/s/ S. Scott Greenberg
S. SCOTT GREENBERG
Nevada Bar No. 4622
5100 W. Sahara Ave.
Las Vegas, Nevada 89146
[phone]
Attorneys for Defendant

By:/s/ Cynthia L Alexander
CYNTHIA L ALEXANDER
Nevada Bar No. 6718
8363 W Sunset Rd, #200
Las Vegas, NV 89113
[phone]
Attorneys for Plaintiff

12
13
14 IT IS SO ORDERED:
15
16
17

Date: June 2, 2017
U.S. MAGISTRATE JUDGE

18
19
20
21
22
23
24
25
26
27
28
-3-