Keith-Henderson v. Clark County School District

Filing 88

ORDER granting 87 Stipulation to Extend Time for Plaintiff to File her Opposition to 77 Motion for Summary Judgment. Responses due by 9/3/2024. Signed by Judge Richard F. Boulware, II on 8/29/2024. (Copies have been distributed pursuant to the NEF - CT)

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KRISTINA S. HOLMAN
Nevada Bar No. 3742
HOLMAN LAW OFFICE
8275 S. Eastern Ave., Suite 215
Las Vegas, Nevada 89123
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Tammie Keith-Henderson

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TAMMIE KEITH-HENDERSON, an
Individual

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STIPULATION AND ORDER TO EXTEND
TIME FOR PLAINTIFF TO FILE HER
OPPOSITION TO DEFENDANT’S
MOTION FOR SUMMARY JUDGMENT

Plaintiff,

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CASE NO.: 2:19-cv-01448- RFB-DJA

v.
CLARK COUNTY SCHOOL DISTRICT, a
political subdivision of the State of Nevada;
DOES I to V; and Roes,

(Fifth Request)

Defendants.

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Plaintiff Tammi Keith-Henderson (“Plaintiff”) and Defendant Clark County School

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District (“Defendant”), by and through their respective counsel of record, hereby stipulate and

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agree that Plaintiff shall have an extension of time up to and including Tuesday, September 3,

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2024, in which to file her opposition to Defendant’s Motion for Summary Judgment (ECF No. 77)

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(filed on June 12, 2024).

This Stipulation is submitted and based on Plaintiff’s counsel’s

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continuing medical appointments and issues as well as a complete day out of the office due to
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computer technology issues on Friday, August 23, 2024. Plaintiff’s counsel, a sole practitioner,

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understands that these extensions were of short periods of time, and yet, unexpected issues arose.

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She worked in earnest on this matter. This case involves a motion for summary judgment, and

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Plaintiff’s counsel continues to engage in her bet efforts. Moreover, opposing counsel, Ms. Foley,

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has been accommodating and understanding.

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The background proceedings are as follows:

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1. Defendant filed its motion for summary judgment on June 12, 2024. Thereafter,

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counsel agreed that Plaintiff could have an extension of time to Wednesday, July 24,

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2024, for Plaintiff to file her Opposition to Defendant’s motion for summary judgment.

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(ECF No. 79). This Court granted that extension. (ECF No. 80).

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2. Plaintiff’s counsel and Defendant’s counsel stipulated to a second extension of time for

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Plaintiff to oppose the Motion for Summary Judgment. (ECF No. 81). The Court

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ordered that the second Stipulation was granted, and the deadline for Plaintiff to file her

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opposition to Defendant’s motion for summary judgment was thereby extended to

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Thursday, August 1, 2024. (ECF No. 82).

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3. Plaintiff’s counsel requested, and opposing counsel agreed, that the time for Plaintiff to

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file her opposition to Defendant’s motion for summary judgment be extended to

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Monday, August 12, 2024. This Court granted that extension (ECF No. 84).

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4. Plaintiff’s counsel requested, and opposing counsel agreed, that the time for Plaintiff to

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file her opposition to Defendant’s motion for summary judgment be extended to

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Tuesday, August 20, 2024.This Court granted that extension. (ECF 86).
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5. This is the fifth request for an extension of time for Plaintiff to file her opposition to

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Defendant’s motion for summary judgment.

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6. This request is made in good faith and not for the purpose of delay.

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Dated: August 28, 2024.

Dated: August 28, 2024.

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CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL
By: /s/Betty J. Foley____
Betty J. Foley
Nevada Bar No. 14517
5100 West Sahara Avenue
Las Vegas, Nevada 89146

HOLMAN LAW OFFICE

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Attorney for Clark County School District

By:

/s/ Kristina S. Holman
Kristina S. Holman
Nevada Bar No. 3742
8275 South Eastern Ave., Suite 215
Las Vegas, Nevada 89123
Attorney for Tammie Keith-Henderson

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ORDER
IT IS SO ORDERED.

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RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
DATED this 29 day of August 2024.

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