Quintana v. Clark County School District et al

Filing 59

ORDER granting 58 Stipulation Re: 57 Motion for Summary Judgment. Responses due by 12/16/2022. Replies due by 1/13/2023. Signed by Judge Cristina D. Silva on 11/21/2022. (Copies have been distributed pursuant to the NEF - HAM) Modified on 11/21/2022 (JLB).

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Case 2:21-cv-00023-CDS-NJK Document 59 Filed 11/21/22 Page 1 of 3 1 2 3 4 5 6 7 8 JAMES P. KEMP, ESQ. Nevada Bar No.: 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No.: 13382 KEMP & KEMP 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 702-258-1183 ph /702-258-6983 fax jp@kemp-attorneys.com vneal@kemp-attorneys.com Attorneys for Plaintiff SARA QUINTANA 9 U.S. DISTRICT COURT 10 FOR THE DISTRICT OF NEVADA 11 ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 SARA QUINTANA, 13 14 15 16 17 18 Plaintiff, vs. CASE NO. 2:21-cv-00023-CDS-NJK 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, Defendants. 19 20 21 22 STIPULATION AND ORDER TO EXTEND THE DEADLINE FOR RESPONSE AND REPLY TO DISPOSITIVE MOTION (FIRST REQUEST) IT IS HEREBY STIPULATED AND AGREED by Plaintiff SARA QUINTANA, through her 23 attorneys JAMES P. KEMP, ESQ. of the law firm of KEMP & KEMP and JAMES A. HILL, ESQ. of 24 the law firm GILBERT EMPLOYMENT LAW, P.C.; and by Defendants CLARK COUNTY 25 SCHOOL DISTRICT (CCSD) and the BOARD OF TRUSTEES OF THE CLARK COUNTY 26 SCHOOL DISTRICT (BOT) through their attorneys WALTER R. CANNON, ESQ. and 27 28 1 Case 2:21-cv-00023-CDS-NJK Document 59 Filed 11/21/22 Page 2 of 3 1 STEPHANIE A. BARKER, ESQ. of the law firm of OLSON CANNON GORMLEY & 2 STOBERSKI, and CRYSTAL J. HERRERA, ESQ. of the OFFICE OF THE GENERAL COUNSEL 3 FOR THE CLARK COUNTY SCHOOL DISTRICT, that the deadline for filing a response to 4 dispositive motions and for filing a reply to a response to dispositive motions in this matter be 5 6 7 extended for twenty-one (21) days. This is the parties FIRST post-discovery request for extension of the respective response and reply deadlines, submitted for the below-stated reasons. 8 On November 4, 2022, Defendants filed Defendants’ Motion for Summary Judgment. (ECF 9 No. 57). The deadline for Plaintiff to file and serve a response to Defendants’ Motion falls on 10 November 25, 2022, which is twenty-one (21) days after service of Defendants’ Motion. See LR 7- 11 2(b). ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 The parties now enter into this first Stipulation to extend the deadline for a response to 13 14 Defendants’ Motion and for a reply to any filed response by twenty-one (21) days. Attorney Kemp, 15 Plaintiff’s counsel, who was in trial during the week of November 7, 2022, will be out of the office 16 from November 16-18, November 21-25, and November 30 through December 2, 2022. Additionally, 17 Attorney Hill, Plaintiff’s counsel, will be out of the office November 24-25, 2022, because his office 18 is closed on those days, and at least some of his support staff will likely be out of the office the week 19 of Thanksgiving (November 21-25, 2022). With the requested extension, the deadline for filing any 20 21 22 reply would fall on December 30, 2022, which is the week following the Christmas holiday and leading up to the New Year’s holiday. See LR 7-2(b). As such, the parties respectfully requests that 23 the deadline for filing a response to Defendants’ Motion be extended until December 16, 2022, and 24 the deadline for filing a reply to any filed response be extended an additional fourteen (14) days until 25 January 13, 2023. 26 /// 27 28 2 Case 2:21-cv-00023-CDS-NJK Document 59 Filed 11/21/22 Page 3 of 3 1 Accordingly, the parties hereby stipulate to extend the current response deadline of November 2 25, 2022, to December 16, 2022, and the reply deadline of December 30, 2022, resulting from the 3 extended response deadline, to January 13, 2023. This is the parties’ FIRST stipulation concerning 4 the deadline for responses to dispositive motions and replies to said responses. 5 RESPECTFULLY SUBMITTED, 6 7 DATED this 16th day of November, 2022. 8 KEMP & KEMP OLSON CANNON GORMLEY & STOBERSKI 9 /s/ James A. Hill /s/ Stephanie Barker JAMES P. KEMP, ESQ. Nevada Bar No. 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No. 13382 7435 W. Azure Drive, Suite 110 Las Vegas, NV 89130 jp@kemp-attorneys.com vneal@kemp-attorneys.com WALTER R. CANNON, ESQ. Nevada Bar No. 001505 STEPHANIE A. BARKER, ESQ. Nevada Bar No. 003176 9950 West Cheyenne Avenue Las Vegas, NV 89129 wcannon@ocgas.com sbarker@ocgas.com AND AND GILBERT EMPLOYMENT LAW, P.C. JAMES A. HILL, ESQ. Pro Hac Vice – ECF 24 1100 Wayne Avenue, Suite 900 Silver Spring, MD 20910 Jhill-efile@gelawyer.com OFFICE OF THE GENERAL COUNSEL, CCSD CRYSTAL J. HERRERA, ESQ. Nevada Bar No. 012396 5100 West Sahara Avenue Las Vegas, NV 89146 Herrec4@nv.ccsd.net Attorneys for Plaintiff Attorneys for Defendants 10 11 ATTORNEYS AT LAW 7435 W. Azure Drive, Suite 110 LAS VEGAS, NEVADA 89130 Tel. (702) 258-1183 ♦ Fax (702) 258-6983 KEMP & KEMP 12 13 14 15 DATED this 16th day of November, 2022. 16 17 18 19 20 21 22 23 24 IT IS SO ORDERED. 25 26 27 UNITED STATES DISTRICT JUDGE DATED: November 21, 2022 28 3

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