Opinion
2:21-cv-00023-CDS-NJK
11-21-2022
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.
KEMP & KEMP /s/ James A. Hill JAMES P. KEMP, ESQ. Nevada Bar No. 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No. 13382 7435 W. Azure Drive, AND GILBERT EMPLOYMENT LAW, P.C. JAMES A. HILL, ESQ. Pro Hac Vice - ECF 24 Attorneys for Plaintiff OLSON CANNON GORMLEY & STOBERSKI /s/ Stephanie Barker WALTER R. CANNON, ESQ. Nevada Bar No. 001505 STEPHANIE A. BARKER, ESQ. Nevada Bar No. 003176 AND OFFICE OF THE GENERAL COUNSEL, CCSD CRYSTAL J. HERRERA, ESQ. Nevada Bar No. 012396 Attorneys for Defendants
KEMP & KEMP /s/ James A. Hill JAMES P. KEMP, ESQ. Nevada Bar No. 6375 VICTORIA L. NEAL, ESQ. Nevada Bar No. 13382 7435 W. Azure Drive, AND GILBERT EMPLOYMENT LAW, P.C. JAMES A. HILL, ESQ. Pro Hac Vice - ECF 24 Attorneys for Plaintiff
OLSON CANNON GORMLEY & STOBERSKI /s/ Stephanie Barker WALTER R. CANNON, ESQ. Nevada Bar No. 001505 STEPHANIE A. BARKER, ESQ. Nevada Bar No. 003176 AND OFFICE OF THE GENERAL COUNSEL, CCSD CRYSTAL J. HERRERA, ESQ. Nevada Bar No. 012396 Attorneys for Defendants
STIPULATION AND ORDER TO EXTEND THE DEADLINE FOR RESPONSE AND REPLY TO DISPOSITIVE MOTION (FIRST REQUEST)
IT IS HEREBY STIPULATED AND AGREED by Plaintiff SARA QUINTANA, through her attorneys JAMES P. KEMP, ESQ. of the law firm of KEMP & KEMP and JAMES A. HILL, ESQ. of the law firm GILBERT EMPLOYMENT LAW, P.C.; and 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, that the deadline for filing a response to dispositive motions and for filing a reply to a response to dispositive motions in this matter be extended for twenty-one (21) days. This is the parties FIRST post-discovery request for extension of the respective response and reply deadlines, submitted for the below-stated reasons.
On November 4, 2022, Defendants filed Defendants' Motion for Summary Judgment. (ECF No. 57). The deadline for Plaintiff to file and serve a response to Defendants' Motion falls on November 25, 2022, which is twenty-one (21) days after service of Defendants' Motion. See LR 7-2(b).
The parties now enter into this first Stipulation to extend the deadline for a response to Defendants' Motion and for a reply to any filed response by twenty-one (21) days. Attorney Kemp, Plaintiff's counsel, who was in trial during the week of November 7, 2022, will be out of the office from November 16-18, November 21-25, and November 30 through December 2, 2022. Additionally, Attorney Hill, Plaintiff's counsel, will be out of the office November 24-25, 2022, because his office is closed on those days, and at least some of his support staff will likely be out of the office the week of Thanksgiving (November 21-25, 2022). With the requested extension, the deadline for filing any reply would fall on December 30, 2022, which is the week following the Christmas holiday and leading up to the New Year's holiday. See LR 7-2(b). As such, the parties respectfully requests that the deadline for filing a response to Defendants' Motion be extended until December 16, 2022, and the deadline for filing a reply to any filed response be extended an additional fourteen (14) days until January 13, 2023.
Accordingly, the parties hereby stipulate to extend the current response deadline of November 25, 2022, to December 16, 2022, and the reply deadline of December 30, 2022, resulting from the extended response deadline, to January 13, 2023. This is the parties' FIRST stipulation concerning the deadline for responses to dispositive motions and replies to said responses.
IT IS SO ORDERED.