Muhammad v. CCSD et al

Filing 15

ORDER granting 14 Stipulation; Amended Complaint deadline: 4/29/2020. Discovery Plan/Scheduling Order due by 5/6/2020. Signed by Judge Richard F. Boulware, II on 3/31/2020. (Copies have been distributed pursuant to the NEF - JM)

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ZARINAH J. MUHAMMAD, ESQ.
NEVADA BAR# 12830
JUSTICE FORCE LAW GROUP
6278 RUBY KINGLET
LAS VEGAS, NV, 89148
PHONE: [phone]
FAX: [phone]
[e-mail]
ATTORNEY FOR PLAINTIFFS

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UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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A.M., a minor by and through her natural
parent and guardian, ZARINAH
MUHAMMAD; ZARINAH MUHAMMAD

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Plaintiffs,

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STIPULATION AND PROPOSED ORDER
TO EXTEND DEADLINES UNDER ECF NO.
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v.
(FIRST REQUEST)

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Case No.: 2:19-cv-00687-RFB-0VCF

CLARK COUNTY SCHOOL DISTRICT;
JESUS JARA; A.J. ADAMS; FELICIA
GONZALES; DIANE LEWIS;
CHRISTOPHER SPARROW; JOHN DOE
DEFENDANTS I THROUGH X; and, ROE
ENTITIES I THROUGH X

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Defendants.

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Plaintiffs A.M., a minor by and through her natural parent and guardian, ZARINAH

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MUHAMMAD and ZARINAH MUHAMMAD (“Plaintiffs”) and Defendants CLARK

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COUNTYSCHOOL DISTRICT; JESUS JARA; A.J. ADAMS; FELICIA GONZALES; DIANE

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LEWIS; and CHRISTOPHER SPARROW (“Defendants”), by and through their attorneys of

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record, hereby stipulate and agree pursuant to Local Rule 7-1 as follows:

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1.

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Whereas, on March 9, 2020, the Court held a hearing on Defendants’ Motion to

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Dismiss (ECF No. 4). The Court granted Plaintiffs leave to amend their complaint and ordered

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Plaintiffs to file the amended complaint by March 30, 2020. ECF No. 13.
2.

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Whereas, the Court also ordered the parties to file a joint discovery plan/scheduling

order by April 6, 2020. ECF No. 13.
3.

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Whereas, on March 15, 2020 Governor Sisolak announced the closure of all K-12

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schools in the State of Nevada; the Governor has since announced a statewide order mandating all

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non-essential businesses to remain closed for 30 days in light of the Coronavirus pandemic that is

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affecting the nation.

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4.

Whereas, the parties are unable to meet the deadlines set by the Court on March 9,

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2020 (ECF No. 13) due to the unexpected Coronoavirus pandemic and the effects of the same.

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More specifically, Plaintiffs require additional time to gather information to file an amended

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complaint and discovery cannot effectively proceed without an amended complaint on file.

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5.

Whereas, the parties agree to a 30-day extension to the deadlines set by the Court

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on March 9, 2020 (ECF No. 13). Plaintiffs’ amended complaint would be due April 29, 2020,

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while the parties’ joint discovery plan/scheduling order would be due May 6, 2020.

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6.

Whereas, this is the first request for an extension regarding the filing of Plaintiffs’

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amended complaint and the time to file a stipulated discovery plan/scheduling order, which is

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made in good faith, not for the purposes of delay, and neither party is prejudiced by the brief

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extension.

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DATED: March 26, 2020

DATED: March 26, 2020

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CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL

JUSTICE FORCE LAW GOUP LLC

By: /s/ Crystal J. Herrera
Crystal J. Herrera (#12396)
5100 West Sahara Avenue
Las Vegas, NV, 89146
Attorney for the Defendants

By: /s/ Zarinah J. Muhammad
Zarinah J. Muhammad (#12830)
6278 Ruby Kinglet
Las Vegas, NV, 89148
Attorney for the Plaintiff

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ORDER

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IT IS SO ORDERED.

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________________________________
RICHARD F. BOULWARE, II
__________________________________________
UNITED STATES DISTRICT JUDGE
UNITED STATES DISTRICT JUDGE
DATED this 31st day of March, 2020.
DATED: __________________________________

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