Chi v. Clark County School District et al

Filing 37

ORDER Granting 36 Stipulation for Extension of Time (Second Request) re 24 Motion to Dismiss, 22 Motion to Dismiss. Responses due by 3/17/2025. Replies due by 4/7/2025. Signed by Judge Cristina D. Silva on 3/3/2025. (Copies have been distributed pursuant to the NEF - ALZ)

1

Plaintiff TERRY CHI, by and through her attorney Robert P. Spretnak, Esq.; Defendants

2

CLARK COUNTY SCHOOL DISTRICT, a political subdivision of the State of Nevada; MARY

3

“MARE” MAZUR, in her official capacity and in her individual capacity; CEDRIC COLE, in his

4

official capacity and in his individual capacity; JESUS JARA, in his official capacity; and

5

BRENDA LARSEN-MITCHELL, in her official capacity, by and through their attorneys Ethan D.

6

Thomas, Esq., Diana G. Dickinson, Esq., and Luke W. Molleck, Esq.; and Defendant SOUTHERN

7

NEVADA PUBLIC TELEVISION, a Nevada nonpr ofit corporation, by and through its attorneys

8

Rusty Graf, Esq., and Paul E. Larsen, Esq.; do hereby stipulate and agree to extend the deadline for

9

Plaintiff TERRY CHI to file her points and authorities in opposition to the following motions to

10

dismiss: (1) Defendants Clark County School District, Mary “Mare” Mazur, Cedric Cole, Jesus Jara,

11

and Brenda Larsen-Mitchell’s Partial Motion To Dismiss [ECF No. 22]; and (2) Defendant Southern

12

Nevada Public Television’s Motion To Dismiss [ECF No. 24] for an additional 17 days, to March

13

17, 2025. This is the second request to extend the time for filing points and authorities in opposition

14

to these motions to dismiss. The first motion to dismiss, ECF No. 22, was filed on January 10, 2025,

15

and, therefore, pursuant to LR 7-2(b), the original deadline for the opposition to that dispositive

16

motion was January 24, 2025. The second motion to dismiss, ECF No. 24, was filed on January

17

14, 2025, and, therefore, pursuant to LR 7-2(b), the original deadline for the opposition to that

18

dispositive motion was January 28, 2025. By prior Stipulation and Order, as approved by this

19

Court, ECF No. 28, these deadlines were extended to February 28, 2025.

20

There is good cause for this additional extension.

21

In the period of since the original deadlines for filing these motions, the schedule for the

22

attorney for Ms. Chi has been completely filled. Ms. Chi’s attorney is a solo practitioner. He was

23

on a scheduled vacation, outside the United States, from January 28, 2025, to February 11, 2025.

24

Upon his return two weeks ago, he prepared and filed oppositions to three dispositive motions in a

25

related case pending in the Clark County District Court, Terry Chi v. Mary “Mare” Mazur, an

26

individual; Debra Solt, an individual; Douglas Bradford, an individual; Michele Kane, an

27
28
T HE

LAW

OFFICES

OF

R O BE R T P. SP RETN A K
A

PR O FE SSIO N A L

C O R P O R A T IO N

8275 S. EA ST E R N AV E N U E
SU IT E 200
LA S VE G A S , NE V A D A 89123

Page 2 of 4

T HE

LAW

1

individual; and Sun City Anthem Community Association, Inc., a Nevada non-profit corporation,

2

Case No. A-24-901963-C. He also attended a deposition in another matter. He has to prepare Early

3

Neutral Evaluation settlement conference statements in two matters pending before this Court,

4

including this case. He has to prepare initial disclosures in this matter prior to the upcoming

5

settlement, which will involve the review and processing of a substantial amount of documentation

6

as part of that process. Thus, counsel has maintained a very full schedule in the period of time

7

covered by the first extension request.

8

Counsel is asking for an additional 17 days, to March 17, 2025, because he will be out of the

9

office the week of March 3, 2025. The following week, the week of March 10, 2025, counsel has

10

two settlement conferences and another settlement conference statement due.

11

The length of time for the extension is further necessitated by the fact that counsel for Ms.

12

Chi is scheduled to be on vacation, out of the country, from January 28, 2025, to February 11, 2025,

13

for a trip that has been postponed once and cannot be postponed or cancelled without incurring a

14

substantial expense.

15

Therefore, for the reasons set forth above, Plaintiff Terry Chi asks for an extension of time

16

to file her points and authorities in opposition to the two pending motions to dismiss in this matter

17

before this Court.

18

Moreover, the parties further stipulate that defendants shall have an additional two weeks to

19

file their respective reply briefs. This is necessitated by the complexity of this matter, specifically

20

in terms of the number of claims at issue, and due to the work schedules of the counsels of record

21

for the defendants. Under LR 7-2(b), reply briefs ordinarily would be seven days after the filing of

22

an opposition brief. In light of the aforementioned extension for Plaintiff Terry Chi to file her points

23

and authorities in opposition to the two pending motions to dismiss, any reply brief in support of

24

either motion would be on March 24, 2025, by operation of LR 7-2(b).

25

....

26

....

27

....

28

....

OFFICES

OF

R O BE R T P. SP RETN A K
A

PR O FE SSIO N A L

C O R P O R A T IO N

8275 S. EA ST E R N AV E N U E
SU IT E 200
LA S VE G A S , NE V A D A 89123

Page 3 of 4