Hurd et al v. Clark County School District et al

Filing 123

ORDER granting 119 Stipulation to Extend Time to Respond/Reply re: 117 Motion to Compel. Responses due by 5/25/2018. Replies due by 6/1/2018. Signed by Magistrate Judge Peggy A. Leen on 5/29/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:16-cv-02011-GMN-PAL Document 119 Filed 05/21/18 Page 1 of 3

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MARK E. FERRARIO, ESQ.
Nevada Bar No. 1625
KARA B. HENDRICKS, ESQ.
Nevada Bar No. 7743
WHITNEY L. WELCH-KIRMSE, ESQ.
Nevada Bar No. 12129
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 N
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
Clark County School District and Shawn Paquette

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GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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;
L.M.V., a minor, by and through his guardian ad
litem, OLIVIA N. ESPINOZA; ZEKROLLAH
SANAEI, ELHAM EGHDAMIAN; and S.S., a
minor, by and through his guardian ad litem,
ZEKROLLAH SANAEI,

Case No. 2:16-cv-02011-GMN-PAL
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR CLARK
COUNTY SCHOOL DISTRICT TO FILE
A RESPONSE TO PLAINTIFFS’
MOTION TO COMPEL DEPOSITION
OF CLARK COUNTY SCHOOL
DISTRICT 30(b)(6) RE PLAINTIFFS’
CATEGORY NO. 53

Plaintiffs,

vs.

[FIRST REQUEST]

CLARK COUNTY SCHOOL DISTRICT;
JAMES P. DORAN; and SHAWN PAQUETTE,

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Defendants.

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Plaintiffs, by and through their undersigned counsel of record, and Defendant, Clark County

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School District (“CCSD”) (collectively, the “Parties”), by and through its undersigned counsel of

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record, hereby stipulate and agree as follows:

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1.

On May 8, 2018, Plaintiffs filed their Motion to Compel Deposition of CCSD’s 30(b)(6)

re Plaintiffs’ Category No. 53 (“Motion to Compel”) [ECF No. 117].
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Case 2:16-cv-02011-GMN-PAL Document 119 Filed 05/21/18 Page 2 of 3

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CCSD’s deadline to file a response to Plaintiffs’ Motion to Compel is May 22, 2018.

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Due to the expert deposition schedule occurring simultaneously, Plaintiffs and CCSD

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have stipulated to allow CCSD additional time to file its response to Plaintiffs’ Motion to Compel up

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to and including May 25, 2018. This is the first request for an extension of time of CCSD’s May 22,

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2018 deadline.

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THEREFORE, the Parties respectfully request an extension for CCSD to file its response to

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Plaintiffs’ Motion to Compel up to and including May 25, 2018. Accordingly, Plaintiffs’ Reply brief

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is now due on or before June 1, 2018. The Parties further stipulate that if Plaintiffs require additional

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time to file their Reply brief, they may have a reciprocal three day extension to June 4, 2018.
DATED this 21st day of May, 2018.

DATED this 21st day of May, 2018.

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GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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GREENBERG TRAURIG, LLP

LAW OFFICES OF PETER ALFERT, PC

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/s/ Whitney L. Welch-Kirmse
MARK E. FERRARIO, ESQ.
Nevada Bar No. 1625
KARA B. HENDRICKS, ESQ.
Nevada Bar No. 7743
WHITNEY L. WELCH-KIRMSE, ESQ.
Nevada Bar No. 12129
3773 Howard Hughes Parkway, Suite 400 N
Las Vegas, NV 89169

/s/ Ian A. Hansen
PETER W. ALFERT, ESQ.
Admitted Pro Hac Vice
IAN A. HANSEN, ESQ.
Admitted Pro Hac Vice
909 Marina Village Parkway, #199
Alameda, CA 94501

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Attorneys for Defendants Clark County School
District and Shawn Paquette

MARIANNE C. LANUTI, ESQ.
Nevada Bar No. 7784
LAW OFFICES OF MARIANNE C. LANUTI
194 Inveraray Court
Henderson, NV 89074
TODD BOLEY, ESQ.
Admitted Pro Hac Vice
LAW OFFICES OF TODD BOLEY
2831 Mariner Square Drive, Suite 280
Alameda, CA 94501
Attorneys for Plaintiffs

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IT IS SO ORDERED:

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_______________________________________
UNITED STATES DISTRICT JUDGE /
UNITED STATES MAGISTRATE JUDGE

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May 29, 2018
DATED: ______________________________

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