Quintana v. Clark County School District et al

Filing 15

ORDER granting 14 Stipulation to Extend Time to Reply to 6 Motion to Dismiss. Replies due by 2/24/2021. Signed by Judge Gloria M. Navarro on 2/16/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:21-cv-00023-GMN-NJK Document 14 Filed 02/12/21 Page 1 of 2
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02/16/21

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CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL
CRYSTAL J. HERRERA, ESQ.
Nevada Bar No. 12396
5100 West Sahara Avenue
Las Vegas, Nevada 89146
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SARA QUINTANA,

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Case No.: 2:21-cv-00023-GMN-NJK

Plaintiff,
v.
CLARK COUNTY SCHOOL DISTRICT, a
political subdivision of the State of Nevada, and
the BOARD OF TRUSTEES OF THE CLARK
COUNTY SCHOOL DISTRICT, in their official
capacities,

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
DEFENDANTS TO FILE REPLY IN
SUPPORT OF THEIR MOTION TO
DISMISS
(FIRST REQUEST)

Defendants.

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Plaintiff Sara Quintana and Defendants Clark County School District (“School

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District”) and the Board of Trustees of the Clark County School District (“Board;” collectively,

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“Defendants”), by and through their respective counsel of record, hereby stipulate to extend the

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time for Defendants to file a reply in support of their Motion to Dismiss (ECF No. 6) from the

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current deadline of February 17, 2021 for seven (7) days, up to and including February 24,

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2021. (ECF No. 13). This is the first request for an extension of time for this deadline.

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Defendants seek the extension of time to allow sufficient time to prepare an appropriate

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reply. Defendants filed a Motion to Dismiss on January 13, 2021 (ECF No. 6). Plaintiff filed a

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Response on February 10, 2021, after receiving a two-week extension (ECF No. 11).

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Accordingly, the deadline for Defendants to file a reply in support of their Motion to Dismiss is

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February 17, 2021.

Counsel requires additional time to evaluate and address Plaintiff’s

Case 2:21-cv-00023-GMN-NJK Document 14 Filed 02/12/21 Page 2 of 2
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02/16/21

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response to administrative exhaustion concerns. Defendants’ counsel will also be taking time

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off through February 16, 2021 in light of the long weekend and will be unable to properly

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evaluate and prepare a reply by the current responsive deadline.

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Based on the foregoing, the parties hereby stipulate to a short extension of time, until

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February 24, 2021, for Defendants to file a reply to their Motion to Dismiss. The one (1) week

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extension will have no significant or prejudicial impact on the proceedings. This request is

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made in good faith and not for the purpose of delay.

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Dated: February 12, 2021.

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CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL

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

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Dated: February 12, 2021.
KEMP & KEMP

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By: James P. Kemp
James P. Kemp, Esq. (#6375)
Victoria L. Neal, Esq. (#13382)
7435 W. Azure Dr., Ste. 110
Las Vegas, NV 89130
Attorney for Plaintiff

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ORDER
IT IS SO ORDERED.
Dated this 16 day of February, 2021.
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__________________________________
Gloria M. Navarro, District Judge
United States District Court
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