Opinion
2:21-cv-00023-CDS-NJK
04-29-2022
SARA QUINTANA, Plaintiff, v. 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.
JAMES R. OLSON, ESQ. Nevada Bar No. 000116 WALTER R. CANNON, ESQ. Nevada Bar No. 001505 STEPHANIE A. BARKER, ESQ. Nevada Bar No. 003176 OLSON CANNON GORMLEY & STOBERSKI AND CLARK COUNTY SCHOOL DISTRICT OFFICE OF THE GENERAL COUNSEL CRYSTAL J. HERRERA, ESQ. Nevada Bar No. 012396 Attorney for DEFENDANTS Clark County School District and Board of Trustees of the Clark County School District GILBERT EMPLOYMENT LAW, PC JAMES A. HILL, ESQ. Attorneys for Plaintiff KEMP & KEMP JAMES P. KEMP, ESQ. Nevada Bar No. 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No. 13382 Attorneys for Plaintiff
JAMES R. OLSON, ESQ.
Nevada Bar No. 000116
WALTER R. CANNON, ESQ.
Nevada Bar No. 001505
STEPHANIE A. BARKER, ESQ.
Nevada Bar No. 003176
OLSON CANNON GORMLEY & STOBERSKI
AND
CLARK COUNTY SCHOOL DISTRICT
OFFICE OF THE GENERAL COUNSEL
CRYSTAL J. HERRERA, ESQ.
Nevada Bar No. 012396
Attorney for DEFENDANTS
Clark County School District and Board of Trustees of the Clark County School District
GILBERT EMPLOYMENT LAW, PC
JAMES A. HILL, ESQ.
Attorneys for Plaintiff
KEMP & KEMP
JAMES P. KEMP, ESQ.
Nevada Bar No. 6375
VICTORIA L. NEAL, ESQ.
Nevada Bar No. 13382
Attorneys for Plaintiff
STIPULATION AND ORDER TO EXTEND THE DISPOSITIVE MOTION DEADLINE (45 DAYS) (FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED by Defendants CLARK COUNTY SCHOOL DISTRICT (CCSD) and the BOARD OF TRUSTEES OF THE CLARK COUNTY SCHOOL DISTRICT (BOT) through their attorneys WALTER R. CANNON, ESQ. and STEPHANIE A. BARKER, ESQ. of the law firm of OLSON CANNON GORMLEY & STOBERSKI, and CRYSTAL J. HERRERA, ESQ. of the OFFICE OF THE GENERAL COUNSEL FOR THE CLARK COUNTY SCHOOL DISTRICT; and by Plaintiff SARA QUINTANA through her attorneys JAMES P. KEMP, ESQ. and VICTORIA L. NEAL, ESQ. of the law firm KEMP & KEMP, and JAMES A. HILL, ESQ. of the law firm GILBERT EMPLOYMENT LAW, P.C., that the dispositive motion deadline in this matter be extended for 45 days. This is the parties FIRST post-discovery request for extension of the dispositive motion deadline.
Discovery closed on April 4, 2022. The dispositive Motion deadline is May 4, 2022 (ECF No. 40). The parties have taken five depositions and exchanged hundreds of pages of documentation in the past three months. Plaintiffs final document disclosure was emailed on April 4, 2022. The record is extensive, and in part, was recently disclosed. In reliance on these records, Defendants intend to file a Motion for Summary Judgment. In addition, the parties are exploring the possibility of settlement conference and wish to avoid incurring attorney fees and costs associated with preparing dispositive motions if settlement is a possibility.
Accordingly, the parties hereby stipulate to a 45-day extension of time to submit dispositive motions, moving the deadline from May 4, 2022, to June 17, 2022.
RESPECTFULLY SUBMITTED.
IT IS SO ORDERED.