Doe v. Clark County School District

1 || THOMAS D. DILLARD, JR., ESQ.

Nevada Bar No. 6270 || STEPHANIE A. BARKER, ESQ.

Nevada Bar No. 3176 || STEPHANIE M. ZINNA, ESQ.

Nevada Bar No. 11488 |};OLSON CANNON & GORMLEY 9950 West Cheyenne Avenue |}Las Vegas, NV 89129 Phone: 702-384-4012 ||Facsimile: 702-383-0701 Email: [email protected] 7 [email protected] 3 [email protected] Attorneys for Defendants 9 Clark County School District and Kemala Washington UNITED STATES DISTRICT COURT DISTRICT OF NEVADA JOHN and JOANN DOE, parents and natural || guardians of JANE DOE, a minor, CASE NO. 2:24-cv-00284-GMN-BNW Ss 14 Plaintiff, § 15 vs. JOINT MOTION TO EXTEND CLARK COUNTY SCHOOL DISTRICT; DEADLINE FOR CLARK COUNTY || CLARK COUNTY EDUCATION SCHOOL DISTRICT AND KEMALA ASSOCIATION; DARRYL L. WASHINGTON TO RESPOND TO || LANCASTER; KEMALA WASHINGTON, COMPLAINT 18 Defendants. (FIRST REQUEST) 20 Plaintiffs, John and Joanne Doe, parents and natural guardians of Jane Doe, a minor || (Plaintiffs), and Defendants Clark County School District (CCSD) and Kemala Washington ||(Washington), collectively the “Moving Parties”, by and through their undersigned counsel, for || good cause shown, hereby move the Court for an extension of time for Defendants CCSD and || Washington to respond to Plaintiffs’ Complaint (ECF No. 1), up to and including February 26, 1/2024: 26 I. Defendants CCSD and Washington, Defendant Clark County Education || Association (CCEA), and Defendant Lancaster jointly removed this action on February 9, 2024 ||(ECF No. 1), making February 16, 2024, the deadline for Defendants to answer or otherwise ||respond to the Complaint. FRCP 81(c)(2)(C).

3 2. Defendants CCSD and Washington require additional time to respond to the □□ Complaint.

5 3. On February 15, 2024, Defendant CCEA and Plaintiffs filed a similar Joint Motion ||to Extend Deadline for Defendant CCEA to Respond to Complaint, agreeing to extend Defendant ||CCEA’s deadline to respond to the Complaint to February 26, 2024. (ECF No. 8).

8 4. The Moving Parties therefore agree to extend the time for Defendants CCSD and || Washington to answer or otherwise respond to the Complaint by 10 days up to and including || February 26, 2024.

It 5. This request is not made for purposes of delay and is supported by good cause.

12 Dated: February 16, 2024. Dated: February 16, 2024.

13 PRINCE LAW GROUP OLSON CANNON & GORMLEY By: 4s/_Colin P. Cavanaugh By: 4s/_ Stephanie A. Barker 5 15 Dennis M. Prince, Esq. (#5092) Thomas D. Dillard, Jr., Esq. (#6270) Colin P. Cavanaugh, Esq. (#13842) Stephanie A. Barker, Esq. (#3176) 16 10801 W. Charleston Blvd. Stephanie M. Zinna, Esq. (#11488) Suite 560 9950 W. Cheyenne Avenue Las Vegas, NV 89148 Las Vegas, NV 89129 a 88 18 Telephone: (702) 534-7600 Telephone: (702) 384-4012 OR Attorneys for Plaintiffs Attorneys for Defendants 19 Clark County School District and 0 Kemala Washington 21 ORDER 22 Good cause appearing, the foregoing Joint Motion is hereby GRANTED. Defendant CCSD’s and Defendant Washington’s deadline to answer or otherwise respond to the Complaint (ECF No. 1) is extended up to and including February 26, 2024. %6 IT IS SO ORDERED. gum la ||DATED: _ 2/20/2024 .

UNITED STATES MAGISTRATE JUDGE I CERTIFICATE OF SERVICE 2 I HEREBY CERTIFY that on the | L day of February, 2024, I served the above and } ||foregoing JOINT MOTION TO EXTEND DEADLINE FOR CLARK COUNTY SCHOOL ||DISTRICT AND KEMALA WASHINGTON TO RESPOND TO COMPLAINT (FIRST 5 REQUEST), through the CM/ECF system of the United States District Court for the District of || Nevada (or if necessary, by electronic mail delivery and by U.S. Mail, first class, postage pre- paid), upon the following: 8 Dennis M. Prince, Esq. John S. Delikanakis, Esq.

9 Colin P. Cavanaugh, Esq. Gil Kahn, Esq.

PRINCE LAW GROUP Markie Betor, Esq.

10 10801 W. Charleston Blvd. SNELL & WILMER L.L.P. Suite 560 3883 Howard Hughes Parkway Las Vegas, NV. 89148 Suite 1100 12 Attorneys for Plaintiffs Attorneys for Defendant Clark County Education Association _ Andrew M. Leavitt, Esq.

14 LAW OFFICES OF 3 ANDREW M. LEAVITT, ESQ. | 633 South 7" Street 6 Las Vegas, NV 89101 Attorney for Defendant Lancaster 7 rf ya NW 18 HO SA he 19 An Employee of OLSON CANNON & GORMLEY Nan Langenderfer From: Colin Cavanaugh <[email protected]> Sent: Friday, February 16, 2024 3:40 PM To: Stephanie Barker Ce: Nan Langenderfer; Dennis Prince; Lisa Lee; Amy Ebinger; Amy Larsen Subject: RE: DOE v. CCSD, CCEA, Washington & Lancaster Hi Stephanie, We are agreeable to the same 10-day extension granted to the other defendants. With that change, it should be good to go. Thanks, Colin Cavanaugh | Attorney | | ) 2 | PRINCE LAW GROUP ms 10801 West Charleston Boulevard, Suite 560 aan Las Vegas, Nevada 89135 renee P: 702.534.7600 | F: 702.534.7601 [email protected] | www.thedple.com From: Stephanie Barker <[email protected]> Sent: Friday, February 16, 2024 3:05 PM To: Colin Cavanaugh <[email protected]> Cc: Nan Langenderfer <[email protected]> Subject: DOE v. CCSD, CCEA, Washington & Lancaster Good Afternoon Colin: In follow up to our phone conversation this morning, attached is a proposed Joint Motion to Extend the time for Defendants CCSD and Washington to respond to the Complaint.

Please advise as to whether you would like changes or, in the alternative, if we have authorization to submit the Joint Motion with your electronic signature.

Thank you for your professional courtesy in this matter.

Stephanie A. Barker, Esq.

Olson Cannon & Gormley 9950 West Cheyenne Avenue Las Vegas, Nevada 89129 Phone: 702-384-4012 Direct: 702-383-1624 [email protected] Privileged and Confidential This email, including attachments, is intended for the person(s) or company named and may contain confidential and/or legally privileged information. Unauthorized disclosure, copying or use of this information may be unlawful and is prohibited. This email and any attachments are believed to be free of any virus or other defect that might affect any computer into which it is received and opened, and it is the