Tims v. Clark County School District

Nevada Bar No. 1625 KARA B. HENDRICKS Nevada Bar No. 7743 WHITNEY L. WELCH-KIRMSE Nevada Bar No. 12129 GREENBERG TRAURIG, LLP 10845 Griffith Peak Drive, Suite 600 Las Vegas, NV 89135 Tel: (702) 792-3773 Fax: (702) 792-9002 Email: [email protected] 7 [email protected] [email protected] Attorneys for Defendants Clark County School District and Mark Connors UNITED STATES DISTRICT COURT DISTRICT OF NEVADA TAMMARA TIMS and H.H., a minor by and CASE NO. 2:18-cv-00021-JAD-VCF through his Guardian Ad Litem, GENEVA ATTEBERRY, 14 STIPULATION AND PROPOSED ORDER Plaintiffs, FOR EXTENSION OF TIME FOR 15 DEFENDANTS TO RESPOND TO vs. PLAINTIFF’S MOTION FOR PARTIAL 16 SUMMARY JUDGMENT [Doc. 206] CLARK COUNTY SCHOOL DISTRICT; and KASEY GLASS, MARK CONNORS, and FOR EXTENSION OF TIME FOR DOES 1-50, PLAINTIFF TO FILE REPLY BRIEF IN 18 SUPPORT OF MOTION FOR PARTIAL Defendants. SUMMARY JUDGMENT (First Request) ECF No. 221 21 IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Clark County School District (“CCSD”) and Mark Connors (collectively “CCSD Defendants”), counsel for Kasey Glass (“Glass”), and counsel for Plaintiff (collectively the “Parties”), as follows: 24 1. On August 21, 2019, Plaintiff filed a Motion for Partial Summary Judgment (Doc. 206) and 25 related declarations.

26 2. The CCSD Defendants and Glass’s deadline to file a response to the Motion for Partial 27 Summary Judgment is September 11, 2019.

28 / / / ] 3. Due to the nature of the issues raised in the Motion for Partial Summary Judgment and the time 2 necessary to respond to the same, the Parties have stipulated to allow an additional 7 days for 3 the CCSD Defendants and Glass to respond to the Motion for Partial Summary Judgment.

4 4. The Parties have also stipulated to allow an additional 7 days for Plaintiff to file any reply to 5 the response filed by the CCSD Defendants and the response filed by Glass.

6 THEREFORE, the Parties respectfully request that the CCSD Defendants and Glass be provided up to and including September 18, 2019 to file their response to Plaintiff's Motion for Partial Summary 8|| Judgment and that Plaintiff has up to and including October 9, 2019 (which is 7 additional days from 9}| the 14 days provided in LR 7-2) for the filing of a reply.

10 This is the Parties’ first request for such extensions.

11 So Stipulated: 12|| DATED this 10™ day of September, 2019. DATED this 10" day of September, 2019.

13]] GREENBERG TRAURIG, LLP LAW OFFICES OF PETER ALFERT, PC /s/ Kara B. Hendricks /s/ Ian Hansen MARK E. FERRARIO, ESQ. PETER W. ALFERT, ESQ. (admitted Pro Hac Vice) Nevada Bar No. 1625 California Bar No. 83139 16]| KARA B. HENDRICKS, ESQ. IAN HANSEN, ESQ. (admitted Pro Hac Vice) Nevada Bar No. 7743 California Bar No. 255449 17|| WHITNEY L. WELCH-KIRMSE, ESQ. 909 Mariner Village Parkway, Suite 199 Nevada Bar No. 12129 Alameda, CA 94501 181] 10845 Griffith Peak Drive, Suite 600 Las Vegas, NV 89135 MICHAEL A. BURKE, ESQ.

191! Counsel for Defendants Clark County School Nevada Bar No. 11527 District and Mark Connors ROBISON SHARP SULLIVAN & BRUST 20 71 Washington Street DATED this 10™ day of September, 2019. Reno, NV 89503 GORDON REES SCULLY TODD A. BOLEY, ESQ. (admitted Pro Hac Vice) 22|| MANSUKHANI, LLP California Bar No. 68119 LAW OFFICES OF TODD BOLEY 23 2381 Mariner Square Drive, Suite 280 /s/ David T. Gluth Alameda, CA 94501 24|| ROBERT S. LARSEN, ESQ. Attorneys for Plaintiffs Nevada Bar No. 7785 25|| DAVID T. GLUTH, II, ESQ Nevada Bar No. 10596 26|| JAMES E. CAVANAUGH, ESQ Based on the parties' stipulation [224], Nevada Bar No. 6929 IT IS SO ORDERED 300 South 4" Street, Ste. 1550 Las Vegas, Nevada 89101 Counsel for Kasey Glass 2 Dyes