Opinion
2:22-cv-01048-JCM-BNW
10-03-2022
DANIELLE MILAM, an individual, Plaintiff, v. KELVIN WATSON, an individual and Executive Director for The Las Vegas-Clark County Library District; THE LAS VEGAS-CLARK COUNTY LIBRARY DISTRICT, a political subdivision of the State of Nevada; and THE LAS VEGAS-CLARK COUNTY LIBRARY DISTRICT FOUNDATION, INC., a Nevada non-profit corporation, Defendants.
KAMER ZUCKER ABBOTT Scott M. Abbott Jen J. Sarafina Attorneys for Defendants Kelvin Watson and Las Vegas- Clark County Library District.
KAMER ZUCKER ABBOTT Scott M. Abbott Jen J. Sarafina Attorneys for Defendants Kelvin Watson and Las Vegas- Clark County Library District.
STIPULATION AND REQUEST FOR STAY OF LITIGATION PROCEEDINGS PENDING THE PARTIES' MEDIATION EFFORTS (FIRST REQUEST)
Plaintiff Danielle Milam and Defendants Kelvin Watson and the Las Vegas-Clark County Library District, by and through their respective counsel of record, stipulate and request that the Court stay all litigation proceedings in this matter for 120 days, up to and including January 31, 2023, to allow the parties an opportunity to engage in mediation and determine whether an early resolution of this matter is possible. In support of this Stipulation and Request, the parties state as follows:
1. Plaintiff filed her Complaint (ECF No. 1) in this matter on July 1, 2022.
2. Pursuant to an agreement between counsel, Defendants Kelvin Watson and die Las Vegas-Clark County Library District (hereinafter “die District”) acknowledged service of the Summons and Complaint on September 13, 2022 (ECF No. 4). Defendants Watson and die District currendy have a deadline of October 4, 2022 to respond to die Complaint.
3. Counsel for Plaintiff and for Defendants Watson and die District have been discussing die potential mediation of this matter to determine whether an early resolution may be achieved. Counsel are currendy in die process of submitting die matter to an outside mediator.
4. This request to stay die proceedings is not sought for any improper purpose or other reason of delay. Radier, it is sought only conserve die expenditures and resources of tiiis litigation while the parties engage in mediation.
5. This is die first request to stay die proceedings in diis matter.
WHEREFORE, the parties respectfully request diat die Court stay the proceedings in this case for 120 days, up to and including January 31, 2023, to allow the parties to engage in mediation efforts.
IT IS SO ORDERED. Counsel is directed to file a status report with the court on February 1, 2023.