Burgess et al v. Clark County School District et al

Filing 80

ORDER Granting 79 Stipulation for Extension of Time re 69 Motion for Partial Summary Judgment, 72 Motion for Summary Judgment (First Request). Replies due by 8/6/2018. Signed by Chief Judge Gloria M. Navarro on 6/30/2018. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5
6

LAW OFFICE OF DANIEL MARKS
DANIEL MARKS, ESQ.
Nevada State Bar No. 002003
[e-mail]
ADAM LEVINE, ESQ.
Nevada State Bar No. 004673
[e-mail]
610 South Ninth Street
Las Vegas, Nevada 89101
[phone]: FAX [phone]
Attorneys for Plaintiff Anthony Russo

7
8

IN THE UNITED STATES DISTRICT COURT

9

FOR THE DISTRICT OF NEVADA

10
11

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

Case No.: 2:17-cv-00805-GMN-VCF

12
Plaintiff,

STIPULATION TO EXTEND THE
DEADLINE FOR FILING OF REPLIES
TO DEFENDANTS’ MOTION FOR
SUMMARY JUDGMENT AND
PLAINTIFF ANTHONY RUSSO’S
MOTION FOR PARTIAL SUMMARY
JUDGMENT ON THE ISSUE OF
LIABILITY
(First Request)

13
v.
14
15
16
17

CLARK COUNTY SCHOOL DISTRICT,
a political subdivsion; EDWARD GOLDMAN,
an individual; JAMES KETSAA, an individual;
CHRISTOPHER KLEMP, an individual,
Defendants.
_____________________________________/

18
19

IT IS HEREBY STIPULATED AND AGREED between the parties, by and through their

20

undersigned counsel to extend for a period of 30 days the current deadlines are Monday, July 2, 2018

21

for Defendants’ Reply and Thursday July 5, 2018 for Plaintiff’s Reply due to Plaintiff’s counsel’s

22

hearing, arbitration, briefing schedule and a preplanned vacation.

23

Plaintiff’s counsel schedule is as follows: July 12 and 13, 2018 Arbitration in the matter of Jeff

24

Harper v. Las Vegas Metropolitan Police Department; July 31 through August 2, 2018 Employee
1

1

Management Relations Board hearing in Burt and Cook v. Las Vegas Metropolitan Police Department,

2

Case No. 2017-034; July 16, 2018 an Answer to Petition for Wirt of Mandamus or Prohibition on

3

behalf of Respondents in City of Mesquite v. The Eighth Judicial District Court for the State of Nevada

4

et al., Nevada Supreme Court Case No. 75743 (Plaintiff’s counsel represents Real Party in Interest

5

Douglas Smaellie in this matter). Further, Plaintiff’s counsel has a prior scheduled prepaid vacation the

6

week of July 16, 2018.

7
8
9

The parties further stipulate that both parties’ Reply be due on the same day, Monday August
6, 2018.
This extension is requested in good faith and not for purposes of delay.

10

DATED this 28th day of June, 2018.

DATED this 28th day of June, 2018.

11

LAW OFFICE OF DANIEL MARKS

GREENBERG TRAURIG, LLP

/s/ Adam Levine , Esq.
DANIEL MARKS, ESQ.
Nevada State Bar No. 002003
[e-mail]
ADAM LEVINE, ESQ.
Nevada State Bar No. 004673
[e-mail]
610 South Ninth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff Anthony Russo

/s/ Kara B. Hendricks, Esq.
,
MARK E. FERRARIO, ESQ.
Nevada State Bar No. 001625
[e-mail]
KARA B. HENDRICKS, ESQ.
Nevada State Bar No. 007743
[e-mail]
3773 Howard Hughes Pkwy., Suite 400 North
Las Vegas, Nevada 89169
Attorneys for Defendants

12
13
14
15
16
17

ORDER

18
19
20

IT IS SO ORDERED.
30
DATED this ____ day of June, 2018.

____________________________________
Gloria M. Navarro, Chief Judge
UNITED STATES DISTRICT COURT

21
22
23
24
2