Hurd et al v. Clark County School District et al

Filing 170

ORDER granting 169 Stipulation. The deadline for Plaintiffs to File a Motion for Attorneys' Fees and Costs is extended two weeks to March 29, 2019. Signed by Magistrate Judge Peggy A. Leen on 3/14/2019. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:16-cv-02011-GMN-PAL Document 169 Filed 03/04/19 Page 1 of 5

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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)

MARK E. FERRARIO, SBN 1625
KARA B. HENDRICKS, SBN 7743
WHITNEY L. WELCH, SBN 12129
GREENBERG TRAURIG, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants Clark County
School District,
Shawn Paquette and Kristy Keller

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PETER W. ALFERT, CA Bar No. 83139
LAW OFFICE PETER ALFERT, P.C.
909 Marina Village Pkwy., 199
Alameda, California 94501
Tel: [phone]
Fax: [phone]
(admitted Pro Hac Vice)

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

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Attorneys for Plaintiffs

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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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;

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

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Defendants.

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PROPOSED STIPULATION
LV 421031861v1

Case No. 2:16-cv-02011-GMN-NJK
STIPULATION EXTENDING DEADLINE
FOR PLAINTIFFS TO FILE MOTION
FOR ATTORNEYS FEES AND COSTS
[SECOND REQUEST]

Case 2:16-cv-02011-GMN-PAL Document 169 Filed 03/04/19 Page 2 of 5

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IT IS HEREBY STIPULATED by and between the parties to the above-entitled action
that:

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Plaintiffs, BROOK M. HURD, GERALDINE C. HURD, and M.H., a minor, by and through

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her guardian ad litem, BROOK M. HURD; LUIS O. VILLALOBOS; OLIVIA N. ESPINOZA;

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L.M.V., a minor, by and through his guardian ad litem, OLIVIA N. ESPINOZA; ZEKROLLAH

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SANAEI, ELHAM EGHDAMIAN; and S.S., a minor, by and through his guardian ad litem,

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ZEKROLLAH SANAEI, and Defendant, Clark County School District (“
CCSD” (collectively, the
)

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“
Parties” by and through its undersigned counsel of record, hereby stipulate and agree as follows:
),

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IT IS HEREBY STIPULATED by and between the parties to the above-entitled action as

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follows:
1.

The parties reached an agreement to settle the above matter at a settlement

conference on November 8, 2018.
2.

On November 14, 2018, the Court issued a Minute Order setting forth the terms

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of that agreement.

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compromise of the minors’claims within 30 days of the School Board’ approval of the
s

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The agreement provides that the plaintiffs shall file a petition for

proposed settlement. In addition, Plaintiffs are to file an application for attorneys’fees and
costs within 30 days of the Board’ approval of the settlement.
s
3.

At the January 16, 2019 status conference the parties indicated that the CCSD

Board was expected to consider the settlement on January 24, 2019.
4.

Due to unforeseen circumstances, the CCSD Board did not consider the

proposed settlement until its meeting on February 14, 2019.
5.

On January 28, 2019, the Court entered a stipulated order extending the deadline

for Plaintiffs’ file a Motion for Attorneys’
to
Fees and Costs to thirty days after the anticipated
board action on February 14, 2019.

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6.

The current deadline for Plaintiffs to file their Motion for Attorneys’Fees and

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Costs is March 15, 2019.
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7.

The parties hereby stipulate to a two-week extension of this deadline making the

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-1PROPOSED STIPULATION
LV 421031861v1

Case 2:16-cv-02011-GMN-PAL Document 169 Filed 03/04/19 Page 3 of 5

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new deadline for Plaintiffs to file their Motion for Attorneys’
Fees and Costs March 29, 2019.

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DATED this 1st day of March, 2019.

DATED this 1st day of March, 2019.

GREENBERG TRAURIG, LLP

LAW OFFICES OF PETER ALFERT, PC

/s/ Kara B. Hendricks
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
10845 Griffith Peak Dr., #600
Las Vegas, NV 89135

/s/ Peter W. Alfert
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

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MARIANNE C. LANUTI, ESQ.
Nevada Bar No. 7784
LAW OFFICES OF MARIANNE C.
LANUTI
194 Inveraray Court
Henderson, NV 89074

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TODD BOLEY, ESQ.
Admitted Pro Hac Vice
LAW OFFICES OF TODD BOLEY
2831 Mariner Square Drive, Suite 280
Alameda, CA 94501

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Attorneys for Plaintiffs

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DATED this 1st day of March, 2019.

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HATFIELD & ASSOCIATES

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/s/
Trevor J. Hatfield
TREVOR J. HATFIELD, ESQ.
Nevada Bar No. 4373
KARA B. HENDRICKS, ESQ.
Attorneys for Defendant James Doran

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-2PROPOSED STIPULATION
LV 421031861v1

Case 2:16-cv-02011-GMN-PAL Document 169 Filed 03/04/19 Page 4 of 5

ORDER

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The deadline for Plaintiffs to File a Motion for Attorneys’Fees and Costs is extended two

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weeks to March 29, 2019.

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IT IS SO ORDERED:

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March 14, 2019
Dated: ____________________

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______________________________________
UNITED STATES MAGISTRATE JUDGE

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-3PROPOSED STIPULATION
LV 421031861v1