Hurd et al v. Clark County School District et al

Filing 115

ORDER Granting 114 Third Stipulation to Modify the Scheduling Order. Motions due by 7/20/2018. Signed by Magistrate Judge Peggy A. Leen on 4/2/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-02011-GMN-PAL Document 114 Filed 03/28/18 Page 1 of 4

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MARIANNE C. LANUTI, SBN 007784
Law Offices of Marianne C. Lanuti
194 Inveraray Court
Henderson, NV 89074
Tel: [phone]
Fax: [phone]
[e-mail]
TODD BOLEY, CA Bar No. 68119
Law Offices of Todd Boley
2831 Mariner Square Dr., Ste 280
Alameda, CA 94501
Tel: [phone]
Fax: [phone]
(admitted Pro Hac Vice)

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PETER W. ALFERT, CA Bar No. 83139
Law Offices Of Peter Alfert, P.C.
200 Pringle Ave., Suite 450
Walnut Creek, California 94596
Tel: [phone]
Fax: [phone]
(admitted Pro Hac Vice)

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MARK E. FERRARIO, SBN 1625
KARA B. HENDRICKS, SBN 7743
WHITNEY L. WELCH, SBN 12129
Greenberg Traurig, LLP
3773 Howard Hughes Parkway, Ste 400 North
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants CLARK COUNTY
SCHOOL DISTRICT,
SHAWN PAQUETTE AND KRISTY
KELLER

Attorneys for PLAINTIFFS

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Attorneys for Defendant JAMES P. DORAN

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TREVOR J. HATFIELD, SBN 7373
Hatfield & Associates, LTD
703 S. 8th Street
Las Vegas, NV 89101
Tel: [phone]
Fax: [phone]
[e-mail]

BROOK M. HURD, GERALDINE C. HURD,
AND M.H., A MINOR, BY AND THROUGH
HER GUARDIAN AD LITEM, BROOK M.
HURD; LUIS O. VILLALOBOS; OLIVIA N.
ESPINOZA; AND L.M.V., A MINOR, BY AND
THROUGH HIS GUARDIAN AD LITEM
OLIVIA N. ESPINOZA;

Case No. 2:16-cv-02011-GMN-NJK
STIPULATION AND
[PROPOSED] ORDER TO MODIFY THE
SCHEDULING ORDER
[THIRD REQUEST]

Plaintiffs,
v.
CLARK COUNTY SCHOOL DISTRICT,
JAMES P. DORAN, SHAWN PAQUETTE,
AND KRISTY KELLER
Defendants.

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STIPULATION AND [PROPOSED] ORDER

2:16-cv-02011-GMN-NJK

Case 2:16-cv-02011-GMN-PAL Document 114 Filed 03/28/18 Page 2 of 4

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WHEREAS, on March 2, 2018 the parties filed a Joint Stipulation and Proposed Order to

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Modify the Scheduling Order (ECF Doc. 109) and the Order was signed by this Court on March

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7, 2018 (ECF Doc. 110); and

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WHEREAS, the Order extended the deadline for the Supplemental Reports of Plaintiffs’
Experts to April 13, 2018; and
WHEREAS, the Order continued the deadline for the Supplemental Rebuttal Reports of
Defendants’Experts to April 27, 2018; and
WHEREAS, the Order continued the deadline by which Expert Depositions must be
completed to May 25, 2018; and
WHEREAS, the Order continued the deadline by which Dispositive Motions must be
filed to June 22, 2018; and
WHEREAS, the parties just concluded the depositions of Defendant CCSD’ 30(b)(6)
s
witnesses on March 19, 2018; and
WHEREAS, the experts for the parties have received the transcripts from twenty-eight

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(28) depositions since their original reports were prepared and require additional time to review

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and consider the testimony and prepare supplemental reports; and

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WHEREAS, counsel for plaintiffs Marianne Lannuti has a prepaid vacation and is
scheduled to be out of the country from April 8, 2018 through April 25, 2018; and
WHEREAS, counsel for plaintiffs Peter Alfert has a prepaid vacation and is scheduled to
be out of the country from May 1, 2018 to May 19, 2018;
IT IS HEREBY STIPULATED by and between the parties to the above-entitled action
that the deadlines are briefly extended as follows:
1. The deadline for Supplemental Reports of Plaintiffs’Experts shall be extended by two
(2) weeks to April 27, 2018;
2. The deadline for Supplemental Rebuttal Reports of Defendants’Experts shall be
extended by two (2) weeks to May 11, 2018;
3. The deadline to complete Expert Depositions shall be extended by two (2) weeks to
June 8, 2018;
-1STIPULATION AND [PROPOSED] ORDER

2:16-cv-02011-GMN-NJK

Case 2:16-cv-02011-GMN-PAL Document 114 Filed 03/28/18 Page 3 of 4

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4. The deadline for Dispositive Motion shall be extended by four (4) weeks to July 20,
2018;

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Date: March 27, 2018

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By: s/ Peter W. Alfert
PETER W. ALFERT
IAN A. HANSEN
Attorneys for Plaintiff

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LAW OFFICES OF PETER W. ALFERT

Date: March 27, 2018

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LAW OFFICES OF MARIANNE C. LANUTI
By: s/ Marianne C. Lanuti
MARIANNE C. LANUTI
Attorneys for Plaintiff

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Date: March 27, 2018

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By: s/ Kara B. Hendricks
KARA B. HENDRICKS
Attorneys for Defendants Clark County School
District, Shawn Paquette, and Kristy Keller

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Date: March 27, 2018

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HATFIELD & ASSOCIATES
By: s/ Trevor J. Hatfield
TREVOR J. HATFIELD
Attorneys for James P. DORAN

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GREENBERG TRAURIG

Date: March 27, 2018

HALL, JAFFE & CLAYTON LLP

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By: s/ Michelle R. Schwarz
STEVEN T. JAFFE
MICHELLE R. SCHWARZ
Attorneys for Defendants Clark County School
District, Shawn Paquette, and Kristy Keller

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-2STIPULATION AND [PROPOSED] ORDER

2:16-cv-02011-GMN-NJK

Case 2:16-cv-02011-GMN-PAL Document 114 Filed 03/28/18 Page 4 of 4

[PROPOSED] ORDER

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Pursuant to the Stipulation of the Parties, and good cause appearing, the following deadlines
are briefly extended as follows:
1. The deadline for Supplemental Reports of Plaintiffs’Experts shall be extended by two
(2) weeks to April 27, 2018;
2. The deadline for Supplemental Rebuttal Reports of Defendants’Experts shall be
extended by two (2) weeks to May 11, 2018;
3. The deadline to complete Expert Depositions shall be extended by two (2) weeks to
June 8, 2018;
4. The deadline for Dispositive Motion shall be extended by four (4) weeks to July 20,
2018;
IT IS HEREBY ORDERED

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April 2
Dated: _______________ , 2018

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__________________________________________
UNITED STATES DISTRICT COURT JUDGE
UNITED STATES MAGISTRATE JUDGE

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-3STIPULATION AND [PROPOSED] ORDER

2:16-cv-02011-GMN-NJK