Hayes v. Clark County School District

Filing 53

ORDER Granting 52 Stipulation for Extension of Time (Second Request) to Extend Joint Pretrial Order Deadline. Proposed Joint Pretrial Order due by 4/4/2025. Signed by Judge Miranda M. Du on 3/6/2025. (Copies have been distributed pursuant to the NEF - ALZ)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16

CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL
CRYSTAL J. HERRERA, ESQ.
Nevada Bar No. 12396
BETTY J. FOLEY, ESQ.
Nevada Bar No. 14517
5100 West Sahara Avenue
Las Vegas, Nevada 89146
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Phillip N. Smith, Jr., Esq.
Nevada Bar No. 10233
[e-mail]
Jacqueline V. Nichols, Esq.
Nevada Bar No. 14246
[e-mail]
WEINBERG, WHEELER, HUDGINS,
GUNN & DIAL, LLC
6385 South Rainbow Blvd., Suite 400
Las Vegas, Nevada 89118
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Clark County School District

17

UNITED STATES DISTRICT COURT

18

DISTRICT OF NEVADA

19
20

FELICIA HAYES,
Plaintiff,

21
22
23
24

v.

Case No. 2:22-cv-02167-MMD-NJK
ORDER GRANTING STIPULATION
AND ORDER TO EXTEND JOINT
PRETRIAL ORDER DEADLINE

CLARK COUNTY SCHOOL DISTRICT,
(SECOND REQUEST)

Defendant.

25
26

Pursuant to LR IA 6-1, LR IA 6-2, LR 26-3, Plaintiff FELICIA HAYES (“Plaintiff”), by

27

and through her attorney of record, and Defendant CLARK COUNTY SCHOOL DISTRICT

28

(“Defendant”), by and through its attorneys of record, hereby stipulate and request that this Court

1

extend the Joint Pretrial Order deadline of March 5, 2025 (ECF 42), for thirty (30) days, up to and

2

including April 4, 2025. This is the second request for an extension of time to the Joint Pretrial

3

Order deadline. This request is made within twenty-one (21) days of the current deadline, and the

4

parties believe there is good cause for the extension.

5

IN CONSIDERATION OF THE FOLLOWING:

6

1. On August 19, 2024, pursuant to the Court’s Order (ECF 42) Granting in Part and

7

Denying in Part Defendant’s Motion for Summary Judgment, pursuant to LR 16-5 this

8

case was referred to the Magistrate Judge for a settlement conference. The Order also

9

directed that if the case did not settle, the parties must file their joint pretrial order 30

10

days after the conclusion of the settlement conference. ECF 42, p. 11.

11

2. A settlement conference was originally scheduled for November 6, 2024 (ECF 43) but

12

did not proceed due to Plaintiff’s counsel’s family medical emergency that day (ECF

13

45). The settlement conference was reset to January 2, 2025 (ECF 47).

14

3. The settlement conference was not successful. (ECF 48).

15

4. The parties have significantly differing views regarding how trial should proceed,

16

based on the Court’s Order (ECF 42) on Defendant’s Motion for Summary Judgment,

17

so the parties entered into a First Stipulation to Extend Joint Pretrial Order Deadline to

18

March 5, 2025. ECF 49.

19
20
21
22

5. On January 23, 2025, the Court entered an Order Granting the [First] Stipulation to
Extend Joint Pretrial Order Deadline to March 5, 2025. ECF 50.
6. The parties have engaged in discussion and exchanged drafts of the Joint Pretrial
Order.

23

7. Defendant has disclosed 24 documents, comprised of approximately 3200 Bates

24

stamped pages. Plaintiff has produced approximately 360 pages in response to written

25

discovery requests. Due to the extensive disclosure record, the parties request

26

additional time to adequately review and resolve disputes they may have regarding the

27

scope of evidence to be presented at trial, in accordance with the requirements outlined

28

in LR 16-3 for a proposed Joint Pretrial Order.
Page 2 of 3

1
2

8. In addition, Defendant has recently retained outside counsel, Jackie V. Nichols, Esq.,
to assist in the trial in this matter.

3

9. In light of the recent retention, Ms. Nichols needs additional time to participate in the

4

pre-trial conferences, including reviewing the above-mentioned records and reviewing

5

the parties’ Joint Pretrial Order thus far.

6

10. This is the parties’ second Stipulation to Extend the Joint Pretrial Order deadline. It is

7

not submitted for the purpose of delay, but rather, is submitted in a good faith effort to

8

narrow and define the scope of evidence to be presented at trial.

9

NOW THEREFORE, THE PARTIES HEREBY STIPULATE that deadline to file the

10

Joint Pretrial Order be extended for an additional 30 days to April 4, 2025. This request is made

11

in good faith and not for the purpose of delay.

12

DATED: 3/5/25

DATED: 3/5/25

13

CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL

PLAINTIFF FELICIA HAYES

By: /s/ Betty Foley
Betty J. Foley, Esq.
Nevada Bar No. 14517
5100 West Sahara Avenue
Las Vegas, NV 89146

By: /s/ Richard Segerblom
Richard Segerblom, Esq.
Nevada Bar No. 1010
602 S. 10th Street
Las Vegas, NV 89101
Attorney for Plaintiff

14
15
16
17
18
19
20
21
22
23
24

Jackie V. Nichols, Esq.
Nevada Bar No. 14246
WEINBERG, WHEELER, HUDGINS,
GUNN & DIAL, LLC
6385 South Rainbow Blvd., Suite 400
Las Vegas, NV 89118
Attorneys for Defendant
Clark County School District
IT IS SO ORDERED.

25
26
27
28

UNITED STATES DISTRICT JUDGE

March 6, 2024
DATED: __________________________________
Page 3 of 3