Burgess et al v. Clark County School District et al

Filing 43

ORDER Granting 40 Stipulation for Extension of Time re 9 Motion to Dismiss (Third Request). Replies due by 9/25/2017. Signed by Chief Judge Gloria M. Navarro on 8/31/17. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6
7
8

Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

9

10

MARK E. FERRARIO
Nevada Bar No. 1625
[e-mail]
KARA B. HENDRICKS
Nevada Bar No. 7743
[e-mail]
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Fax:
[phone]
Attorneys for Defendants
Clark County School District,
Edward Goldman, James Ketsaa and
Christopher Klemp

11
12
13

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

14

DANIEL M. BURGESS, an individual;
ANTHONY RUSSO, an individual,

17

CLARK COUNTY SCHOOL DISTRICT, a
political subdivision; EDWARD GOLDMAN,
an individual; JAMES KETSAA, an
individual; CHRISTOPHER KLEMP, an
individual,

15
16
18
19
20
21

vs.

Plaintiffs,

Case No. 2:17-cv-00805-GMN-VCF
STIPULATION FOR EXTENSION OF
TIME TO FILE REPLY IN SUPPORT OF
MOTION TO DISMISS BURGESS’
CLAIMS
(Third Request)

Defendants.
It is hereby STIPULATED AND AGREED between Plaintiff Daniel M. Burgess

22

(“Burgess”) and Defendants, by and through their undersigned counsel, that Defendants will have

25

to finalize a settlement agreement, and wish to avoid incurring additional costs and fees while they

28

timeframe in which to file the reply. Defendants’ motion to dismiss Burgess’ claims was filed on

23

additional time to file their reply in support of their motion to dismiss Burgess’ claims up to and

26

actively pursue settlement. This Court has provided the parties until September 25, 2017 to file a

24

including September 25, 2017. This extension is requested as the parties are currently attempting

27

stipulation dismissing the action. See ECF No.39. This extension allows Defendants the same

LV 420973663v1 120810.011700

1

1
2
3

May 26, 2017 (ECF No. 10). Pursuant to stipulated extensions of time, Plaintiff Burgess filed his
opposition on July 11, 2017, and Defendants’ reply is currently due on August 30, 2017. This is the

4

third request for an extension of time to file the Burgess reply, as settlement discussions have been

6
7

the other plaintiff, Anthony Russo.

9

DATED this 29th day of August, 2017.

DATED this 29th day of August, 2017.

GREENBERG TRAURIG, LLP

MAIER GUTIERREZ & ASSOCIATES

/s/ Kara B. Hendricks
MARK E. FERRARIO, ESQ.
Nevada Bar No. 1625
KARA B. HENDRICKS, ESQ.
Nevada Bar No. 7743
3773 Howard Hughes Parkway, Suite 400 N
Las Vegas, NV 89169
Counsel for Defendants

/s/ Jason R. Maier
JOSEPH A. GUTIERREZ, ESQ.
Nevada Bar No. 9046
JASON R. MAIER, ESQ.
Nevada Bar No. 8557
8816 Spanish Ridge Avenue
Las Vegas, NV 89148
Counsel for Plaintiff Daniel M. Burgess

5

Greenberg Traurig, LLP
3773 Howard Hughes Parkway - Suite 400 North
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

8

10
11
12
13
14
15
16
17
18
19
20

ongoing.
The above-stipulated extension does not affect ongoing proceedings in this case involving

IT IS SO ORDERED.

31
Signed this _____ day of August, 2017.

21
22

_____________________________________
GLORIA M. NAVARRO, CHIEF JUDGE
UNITED STATES DISTRICT COURT

23
24
25
26
27
28

LV 420973663v1 120810.011700

2