Batiste v. Clark County School District et al

Filing 32

ORDER granting 31 Stipulation; Motions due by 4/13/2018. Signed by Magistrate Judge George Foley, Jr on 3/8/2018. (Copies have been distributed pursuant to the NEF - JM)

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Case 2:17-cv-00227-APG-GWF Document 31 Filed 03/07/18 Page 1 of 2 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 (702) 799-5373 Attorney for Defendants 5 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 ANDRE BATISTE, 9 10 11 12 13 14 15 CASE NO. 2:17-cv-00227-APG-GWF STIPULATION TO DEADLINE (Second Request) Plaintiff, v. EXTEND MOTION CLARK COUNTY SCHOOL DISTRICT; JON HOWARD, an individual; DOES I-X, inclusive, and ROE ENTITIES I-X, inclusive, Defendants. COME NOW, the parties, by and through their attorneys of 16 record, and hereby stipulate and agree to extend the motion deadline 17 thirty (30) days from the current deadline of March 14, 2018, up to 18 and including April 13, 28014. This is the second request to extend 19 the motion deadline. This request is made in good faith for the 20 reasons described below and not for any reason of delay. 21 The parties completed depositions during the last week of the 22 discovery period and have been waiting for transcripts from said 23 depositions. 24 reporter’s There office was a delaying mis-communication receipt of with Plaintiff’s the court deposition 25 transcript and it is believed the transcript will be available on 26 March 9, 2018. Defendant Howard is retired from the District and 27 it has also taken longer than anticipated to obtain necessary input 28 from him for defendants’ dispositive motion. Furthermore, defense Case 2:17-cv-00227-APG-GWF Document 31 Filed 03/07/18 Page 2 of 2 1 counsel has been working on other litigation matter deadlines 2 including a proposed pre-trial order in Case Case No. 2:15-cv-007933 APG-GWF and a Nevada Supreme Court opening brief due March 20, 2018, 4 in Nevada Supreme Court Case No. 73348. Additionally, counsel have 5 had positive settlement discussions which they reasonably believe 6 may resolve the matter without the necessity of filing dispositive 7 motions. 8 Therefore, the parties respectfully request that the motion 9 deadline be extended thirty (30) days up to and including April 13, 10 2018. 11 DATED this 7th day of March, 2018. 12 CLARK COUNTY SCHOOL DISTRICT Office of the General Counsel 13 14 By: 15 16 17 /s/ S. Scott Greenberg S. SCOTT GREENBERG Nevada Bar No. 4622 5100 W. Sahara Ave. Las Vegas, Nevada 89146 (702) 633-8911 Attorney for CCSD By: /s/ F. Travis Buchanan F. TRAVIS BUCHANAN Nevada Bar No. 9371 701 E. Bridger Ave., #540 Las Vegas, NV 89101 (702) 943-0305 Attorney for Plaintiff 18 19 20 21 IT IS SO ORDERED: 22 23 24 Date: 3/8/2018 U.S. MAGISTRATE JUDGE 25 26 27 28 -2-

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