Tims et al v. Clark County School District et al

Filing 245

ORDER granting 244 Stipulation. This case is STAYED and all deadlines for any action required to be taken by any party be tolled until further order by the Court. IT IS FURTHER ORDERED that any hearing currently set is VACATED. IT IS FURTHER ORDERED that a Status Check is set for 3/11/2020 at 04:00 PM in LV Courtroom 6D before Judge Jennifer A. Dorsey. Signed by Judge Jennifer A. Dorsey on 12/13/2019. (Copies have been distributed pursuant to the NEF - DC)

Case 2:18-cv-00021-JAD-VCF Document 244 Filed 12/13/19 Page 1 of 3
1 MARK E. FERRARIO

Nevada Bar No. 1625

2 KARA B. HENDRICKS

Nevada Bar No. 7743

3 WHITNEY L. WELCH-KIRMSE

Nevada Bar No. 12129

4 GREENBERG TRAURIG, LLP

10845 Griffith Peak Drive, Ste. 600

5 Las Vegas, NV 89135

Tel:

[phone]
[phone]
Email: [e-mail]
[e-mail]
7
[e-mail]
6 Fax:

8

Attorneys for Defendants

9 Clark County School District and Mark Connors
10

UNITED STATES DISTRICT COURT

11

DISTRICT OF NEVADA

12 TAMMARA TIMS and H.H., a minor by and

CASE NO. 2:18-cv-00021-JAD-VCF

through his Guardian Ad Litem, GENEVA
13 ATTEBERRY,
14

Plaintiffs,

STIPULATION AND REQUEST TO
STAY LITIGATION PENDING
SATISFACTION OF SETTLEMENT
TERMS AND EXECUTION OF
SETTLEMENT AGREEMENT

15 vs.
16 CLARK COUNTY SCHOOL DISTRICT;

KASEY GLASS, MARK CONNORS, and DOES

17 1-50,
18

ECF No. 244

Defendants.

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20

Plaintiff H.H., a Minor, by and through his Guardian Ad Litem, Geneva Atteberry (“Plaintiff”),

21 by and through his counsel of record, and Defendants Clark County School District, Kasey Glass, and
22 Mark Connors (collectively “Defendants”), by and through their counsel of record, hereby request that
23 the Court stay this matter while the parties work on satisfying agreed-upon settlement terms reached at
24 mediation. The parties state as follows:
25

1.

On December 11, 2019, the parties attended a mediation session, which resulted in a

26 preliminary agreement of settlement terms.
27

2.

A stay in this matter will allow the parties the opportunity to satisfy preliminary terms of

28 the settlement, including finalizing the settlement agreement, seeking approval from CCSD’s Board of

ACTIVE 47619872v1

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Case 2:18-cv-00021-JAD-VCF Document 244 Filed 12/13/19 Page 2 of 3
1 Trustees regarding settlement terms, and seeking Court approval regarding the Minor’s Compromise,
2 prior to dismissing this matter.

3.

3

The parties stipulate that this case be stayed and that the deadline for any action required

4 to be taken by any party be tolled until further order of the court.
5

4.

The parties request that a status check be set for 90 days.

6

5.

This stipulation is made in good faith to allow the parties to make diligent and sincere

7 efforts to resolve the matter without further involvement for the Court and is not for the purpose of
8 causing any undue delay.

IT IS SO STIPULATED.

9

10 DATED this 13th day of December, 2019.

DATED this 13th day of December, 2019.

11 GREENBERG TRAURIG, LLP

LAW OFFICES OF PETER ALFERT, PC

12

/s/ Kara B. Hendricks

/s/ Peter W. Alfert
PETER W. ALFERT, ESQ. (Pro Hac Vice)
California Bar No. 83139
IAN HANSEN, ESQ. (Pro Hac Vice)
California Bar No. 255449
909 Mariner Village Parkway, Suite 199
Alameda, CA 94501

13 MARK E. FERRARIO, ESQ.

Nevada Bar No. 1625

14 KARA B. HENDRICKS, ESQ.

Nevada Bar No. 7743

15 WHITNEY L. WELCH-KIRMSE, ESQ.

Nevada Bar No. 12129

16 10845 Griffith Peak Drive, Suite 600

Las Vegas, NV 89135

MICHAEL A. BURKE, ESQ.
Nevada Bar No. 11527
ROBISON SHARP SULLIVAN & BRUST
71 Washington Street
Reno, NV 89503

17 Counsel for Defendants Clark County School
18
19

District and Mark Connors

DATED this 13th day of December, 2019.

TODD A. BOLEY, ESQ. (Pro Hac Vice)
California Bar No. 68119
LAW OFFICES OF TODD BOLEY
2381 Mariner Square Drive, Suite 280
Alameda, CA 94501
Attorneys for Plaintiff

20 GORDON REES SCULLY MANSUKHANI,

LLP

21

/s/ David T. Gluth

22 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785

23 DAVID T. GLUTH, ESQ.

Nevada Bar No. 10596
300 S. 4th Street, Suite 1550
25 Las Vegas, NV 89101
Attorneys for Kasey Glass
24

26

ORDER

27
28

In consideration of the stipulation by the parties, [ECF No. cause and with good cause appearing,
and with 244], appearing,

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Case 2:18-cv-00021-JAD-VCF Document 244 Filed 12/13/19 Page 3 of 3
1

is STAYED; and that all the deadline any action
IT IS HEREBY ORDERED that this case shall be stayed and that deadlines for for any action

2 required to be taken by any party be tolled until further order by the Court.
3

IT IS FURTHER ORDERED that any hearing currently set shall be vacated.
is VACATED;

4

11th
IT IS FURTHER ORDERED that a status check in this matter will occur on the _____ day of

March
5 ____________________, 2020 at ____ a.m./p.m.
4:00 p.m.
6

IT IS SO ORDERED.

7

13th
DATED this _____ day of December, 2019.

8
9

_______________________________________
UNITED STATES DISTRICT COURT JUDGE

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ACTIVE 47619872v1

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