American Preparatory Schools, Inc. v. Nevada Charter Academies

Filing 92

ORDER Granting 91 Stipulation for Extension of Time re 83 Third Amended Complaint (Fourth Request). Rachelle Hulet; Nevada Charter Academies answer due 5/12/2021. Signed by Magistrate Judge Nancy J. Koppe on 2/16/2021. (Copies have been distributed pursuant to the NEF - MR)

Case 2:20-cv-01205-JAD-NJK Document 91 Filed 02/12/21 Page 1 of 4
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LIPSON NEILSON P.C.
JOSEPH P. GARIN, ESQ.
Nevada Bar No. 6653
LISA J. ZASTROW, ESQ.
Nevada Bar No. 9727
9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants Nevada Charter Academies d/b/a
American Preparatory Academy- Las Vegas
UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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***
AMERICAN PREPARATORY SCHOOLS,
) Case No: 2:20-cv-01205-JAD-NJK
INC., a Utah Corporation,
)
) STIPULATION AND ORDER TO
Plaintiff,
) EXTEND TIME FOR FILING OF
vs.
) RESPONSES TO THIRD AMENDED
) COMPLAINT
NEVADA CHARTER ACADEMIES d/b/a
)
AMERICAN PREPARATORY ACADEMY – ) (FOURTH REQUEST)
LAS VEGAS, a Nevada Corporation, and
)
RACHELLE HULET, an individual,
)
)
Defendants.
)
______________________________________

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Plaintiff American Preparatory Schools, Inc. (“Plaintiff”), by and through its counsel of

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record, the law firms of Parr Brown Gee & Loveless and the Takos Law Group, LTD., Defendant
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Nevada Charter Academies d/b/a American Preparatory Academy – Las Vegas (“APA”), by and
through its counsel of record, the law firms of Lipson Neilson P.C. and Hayes Wakayama, and

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LIPSON NEILSON P.C.

9900 Covington Cross Drive, Suite 120, Las Vegas, Nevada 89144
Telephone: [phone] Facsimile: [phone]

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Defendant Rachelle Hulet (“Hulet”), by and through her counsel of record, the law firm of Hogan
Hulet, (collectively the “Parties”), hereby stipulate and agree as follows:
/././

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/././

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Case 2:20-cv-01205-JAD-NJK Document 91 Filed 02/12/21 Page 2 of 4
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1.

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On December 16, 2020, this Court filed an Order instructing the Plaintiff to file its

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Third Amended Complaint no later than December 18, 2020, and Defendants to file their responses

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to Plaintiff’s Third Amended Complaint by January 15, 2021 [ECF No. 82].

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2.

On December 16, 2020, Plaintiff filed its Third Amended Complaint [ECF No. 83].

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3.

On January 12, 2021, a Notice of Appearance of Co-Defense Counsel was filed

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noticing the appearance of the law firm of Hayes Wakayama as co-defense counsel for Defendant

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APA, together with the law firm of Lipson Neilson [ECF No. 84].
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Plaintiff’s Third Amended Complaint for two weeks from January 15, 2021 up through and
including January 29, 2021. [ECF 87].
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to settlement discussions, setting the current deadline to February 12, 2021. [ECF 90]
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The Parties once again agreed to extend the deadline for an additional two weeks due

The reason for the Parties’ requesting this instant fourth extension is that the parties

have agreed to privately mediate this matter.
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It is accordingly in the best interest of all Parties not to publish the Defendants’

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responses to the Third Amended Complaint at this time insomuch as the Parties have agreed that a

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ninety-day extension will allow for enough time for the Parties to mediate.
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While in a typical case, private mediation would not necessitate more than sixty

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days, here a ninety-day extension is necessary given any resolution will require approval by

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the Defendant School Board.
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Therefore, the Parties agree to extend the deadline from February 12, 2021 to May

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12, 2021.

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NO FURTHER EXTENSIONS WILL BE GRANTED.
/././

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/././
IT IS SO ORDERED.

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LIPSON NEILSON P.C.

9900 Covington Cross Drive, Suite 120, Las Vegas, Nevada 89144
Telephone: [phone] Facsimile: [phone]

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The Parties agreed to extend the deadline for Defendants’ to file their responses to

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/././
Dated: February 16, 2021
/././

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/././

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________________________
United States Magistrate Judge

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