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)

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 [phone]
Attorney for Defendants
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

8

ANDRE BATISTE,

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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.
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DATED this 7th day of March, 2018.

12 CLARK COUNTY SCHOOL DISTRICT
Office of the General Counsel
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14 By:
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/s/ S. Scott Greenberg
S. SCOTT GREENBERG
Nevada Bar No. 4622
5100 W. Sahara Ave.
Las Vegas, Nevada 89146
[phone]
Attorney for CCSD

By: /s/ F. Travis Buchanan
F. TRAVIS BUCHANAN
Nevada Bar No. 9371
701 E. Bridger Ave., #540
Las Vegas, NV 89101
[phone]
Attorney for Plaintiff

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21 IT IS SO ORDERED:
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24 Date: 3/8/2018
U.S. MAGISTRATE JUDGE
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