Dwedar v. State of Nevada Ex Rel. Board of Regents of the Nevada System of Higher Education, on Behalf of the University of Nevada, Reno

Filing 11

ORDER granting 10 STIPULATION FOR EXTENSION OF TIME (First Request) re: 1 Complaint. Response/Answer due 3/21/2025. Signed by Magistrate Judge Carla Baldwin on 3/12/2025. (Copies have been distributed pursuant to the NEF - GA)

1 OFFICE OF THE GENERAL COUNSEL
Claudia E. Aguayo, General Counsel (SBN 8351)
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Frank Z. LaForge, Assistant General Counsel (SBN 12246)
3 Scott H. Husbands, Assistant General Counsel (SBN 11398)
University of Nevada, Reno
4 1664 N. Virginia Street/MS0550
5 Reno, Nevada 89557-0550
[phone]
6 [phone] fax
[e-mail]
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[e-mail]
8 [e-mail]
9 Attorneys for Defendant
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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13 DAHLIA DWEDAR,
Plaintiff,

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Case No. 3:24-CV-00583-MMD-CLB
ORDER GRANTING STIPULATION
REGARDING TIME TO FILE
RESPONSIVE PLEADING
(First Request)

v.

16 STATE OF NEVADA EX REL. BOARD OF
REGENTS OF THE NEVADA SYSTEM OF
17 HIGHER EDUCATION, ON BEHALF OF
THE UNIVERSITY OF NEVADA RENO,
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Defendant.
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Plaintiff Dahlia Dwedar (“Plaintiff”) appearing through counsel of record Trevor J.
Hatfield, Esq., Defendant Board of Regents of the Nevada System of Higher Education on
behalf of the University of Nevada, Reno (“UNR”) appearing through counsel of record Claudia
E. Aguayo, Esq., Frank Z. LaForge, Esq. and Scott H. Husbands, Esq., hereby stipulate that
UNR shall have up to and including March 21, 2025 to file its responsive pleading to Plaintiff’s

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Complaint. In support of their stipulation, the Parties provide the following pursuant to and in

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compliance with LR IA 6-1, LR IA 6-2, and LR 7-1:

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1. Plaintiff filed her Complaint on December 17, 2024. (ECF No. 1)

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2. Plaintiff served UNR on February 4, 2025. (ECF No. 7) Under FRCP 12, assuming

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service was complete, UNR’s responsive pleading would have been due on February

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25, 2025.

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3. On February 24, 2025, UNR’s counsel reached out to Plaintiff’s counsel to discuss a

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proposed extension of two weeks. UNR’s need for the extension was largely based

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on counsel of record in this matter being occupied with another lawsuit in federal

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court. That issue, and other pre-existing professional obligations, left UNR without

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the time it needed to prepare and file its responsive pleading. Plaintiff’s counsel

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agreed to the request for a continuance and counsel stipulated to request a two-week

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extension.

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discovered that Plaintiff had not filed a necessary affidavit of service showing

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service on the Office of the Attorney General.

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Plaintiff’s counsel to advise of the issue and that no responsive pleading was due

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because it appeared service was incomplete. Plaintiff filed the necessary affidavit of
UNR did not discover that the affidavit was filed until March 10, 2025. At that time,

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UNR’s counsel reached out to Plaintiff’s counsel to discuss a new responsive

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pleading deadline. Counsel agreed that UNR would have up to and including March

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21, 2025 to file its responsive pleading.
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UNR’s counsel reached out to

service on February 26 but did not reach out to UNR’s counsel regarding the filing.

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Following counsel’s agreement on a two-week stipulation, UNR

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4. This is the Parties’ first stipulation to extend the time for UNR to file its responsive
pleading.
5. The Parties therefore request that UNR have up to and including March 21, 2025 to
submit its responsive pleading to Plaintiff’s Complaint.
6. The Parties offer this stipulation in good faith and not for the purpose of delay.
STIPULATED and DATED this 12th day of March, 2025.
/s/ Scott H. Husbands
Claudia E. Aguayo (SBN 8351)
Frank Z. LaForge (SBN 12246)
Scott H. Husbands (SBN 11398)
Office of the General Counsel
University of Nevada, Reno
1664 N. Virginia Street/MS0550
Reno, Nevada 89557-0550
[phone]
[phone] fax
[e-mail]
[e-mail]
[e-mail]

/s/ Trevor J. Hatfield
Trevor J. Hatfield (SBN 7373)
Hatfield & Associates, Ltd.
703 S. 8th Street
Las Vegas, Nevada 89101
[phone]
[phone] fax
[e-mail]
Attorney for Plaintiffs

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Attorneys for Defendant

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IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE
DATED:

March 12, 2025

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