Cox et al v. Lewis et al

Filing 63

ORDER Granting 62 Stipulation for Extension of Time (First Request) to Extend Response to Dispositive Motion Deadline re 56 Order on Stipulation re 59 Motion for Summary Judgment. IT IS SO ORDERED that Plaintiffs' counsel will have 30 days to file a response to the CCSD Defendants' Motion for Summary Judgment, which response will be due no later than October 6, 2022. Signed by Judge James C. Mahan on 9/16/2022. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:20-cv-01792-JCM-BNW Document 63 Filed 09/16/22 Page 1 of 3

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JASON J. BACH
Nevada Bar No. 7984
THE BACH LAW FIRM, LLC
7881 West Charleston, Suite 165
Las Vegas, Nevada 89117
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Plaintiffs

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MICHELLE COX, individually, and as parent
and next friend of M.C.,
Plaintiffs,

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v.
RYAN LEWIS, individually, and in his official
capacity; JORGE PALACIOS, individually,
and in his official capacity; and CLARK
COUNTY SCHOOL DISTRICT,

Case No.: 2:20-cv-01792-JCM-BNW
STIPULATION AND ORDER
TO EXTEND RESPONSE TO
DISPOSITIVE MOTION DEADLINE
(FIRST REQUEST)

Defendants.

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Plaintiffs Michelle Cox, individually, and as a parent and next friend of M.C.,

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(“Plaintiffs”), by and through their counsel of record, Jason J. Bach, of The Bach Law Firm, LLC,

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and Defendants Clark County School District (“CCSD”), Ryan Lewis (“Lewis”), and Jorge

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Palacios (“Palacios”) (collectively, the “CCSD Defendants” and, together with Plaintiffs, the

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“Parties”), by and through their counsel of record, Craig R. Anderson and Jackie V. Nichols, of

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Marquis Aurbach, hereby agree and jointly stipulate the following:

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1.

This request for an extension of time is not sought for an improper purpose or other

purpose of delay. This is the first request for extension of time to respond in this matter.
2.

On August 31, 2022, the Parties filed a Stipulation and Order to Extend the

Dispositive Motion Deadline [Docket No. 55], up to and including September 6, 2022, and to

Case 2:20-cv-01792-JCM-BNW Document 63 Filed 09/16/22 Page 2 of 3

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extend the time for Plaintiffs to file their response to CCSD Defendants’ Dispositive Motion up to

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and including October 6, 2022.
3.

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On September 1, 2022, the Court entered an Order Granting and Denying in Part

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the Parties’ Stipulation and Order [Docket No. 56]. By such Order, the Court granted the Parties’

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request to extend the Dispositive Motion deadline but denied the Parties’ request to extend

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Plaintiffs’ response-brief deadline and stated that the Parties must file a separate stipulation

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seeking this relief pursuant to LR IC 2-2(b).
4.

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On September 6, 2022, the CCSD Defendants filed a Motion to Exceed Page Limit

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on their Motion for Summary Judgment [Docket No. 57] and a Motion for Leave to File Under

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Seal [Docket No. 58], which remain pending before the Court at the time of filing this Stipulation.

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Also, on September 6, 2022, the CCSD Defendants filed a Motion for Summary Judgment [Docket

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No. 59].
5.

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Pursuant to the CCSD Defendants’ Motion to Exceed Page Limit on their Motion

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for Summary Judgment, the CCSD Defendants anticipated filing a 60-page Motion for Summary

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Judgment and, in fact, the Motion for Summary Judgment filed by the CCSD Defendants

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numbered 63 pages. Plaintiffs are requesting additional time to respond to the CCSD Defendants’

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oversized Motion.

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6.

Additionally, counsel for Plaintiff was out of the country from September 9, 2022,

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through September 13, 2022, and in addition to his normal caseload, counsel for Plaintiff will need

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to prepare and act as Mediator in the ACF Finco I, LP v. Taylor Metal, Inc. d/b/a Taylor Metal

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Products, United States Bankruptcy Court for the District of Nevada (Las Vegas), Case No. 2:21-

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ap-01254-mkn.
7.

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The Parties respectfully submit that the reasons set forth above constitute

compelling reasons for the modest extension of time.
8.

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WHEREFORE, Plaintiffs’ counsel will have 30 days to file a response to the CCSD

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Defendants’ Motion for Summary Judgment, which response will be due no later than October 6,

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2022.

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Case 2:20-cv-01792-JCM-BNW Document 63 Filed 09/16/22 Page 3 of 3

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9.

This Stipulation is being entered in good faith and not for purposes of delay.

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IT IS SO STIPULATED AND AGREED.

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Dated this 14th day of September, 2022.

Dated this 14th day of September, 2022.

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THE BACH LAW FIRM, LLC

MARQUIS AURBACH COFFING

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By: /s/ Jason J. Bach
Jason J. Bach
Nevada Bar No. 7984
7881 W. Charleston Blvd., Suite 165
Las Vegas, NV 89117
Attorneys for Plaintiff

By: /s/ Jackie V. Nichols
Craig R. Anderson
Nevada Bar No. 6882
Jackie V. Nichols
Nevada Bar No. 14246
10001 Park Run Drive
Las Vegas, Nevada 89145

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Clark County School District
Office of the General Counsel
Crystal J. Herrera
Nevada Bar No. 12396
5100 West Sahara Avenue
Las Vegas, Nevada 89146
Attorneys for Defendant

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ORDER

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The above Stipulation is hereby GRANTED.

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16 day of September, 2022, that Plaintiffs’ counsel will have
IT IS SO ORDERED this ___

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30 days to file a response to the CCSD Defendants’ Motion for Summary Judgment, which

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response will be due no later than October 6, 2022.

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UNITED STATES DISTRICT JUDGE

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