Doe v. Clark County School District ( 2024 )

1 || THOMAS D. DILLARD, JR., ESQ. Nevada Bar No. 6270 2 || STEPHANIE A. BARKER, ESQ. Nevada Bar No. 3176 3 || STEPHANIE M. ZINNA, ESQ. Nevada Bar No. 11488 4 |};OLSON CANNON & GORMLEY 9950 West Cheyenne Avenue 5 |}Las Vegas, NV 89129 Phone: 702-384-4012 6 ||Facsimile: 702-383-0701 Email: tdillard@ocgas.com 7 sbarker@ocgas.com 3 szinna@ocgas.com Attorneys for Defendants 9 Clark County School District and Kemala Washington 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 12 JOHN and JOANN DOE, parents and natural 13 || 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 16 || CLARK COUNTY EDUCATION SCHOOL DISTRICT AND KEMALA ASSOCIATION; DARRYL L. WASHINGTON TO RESPOND TO 17 || LANCASTER; KEMALA WASHINGTON, COMPLAINT 18 Defendants. (FIRST REQUEST) 20 Plaintiffs, John and Joanne Doe, parents and natural guardians of Jane Doe, a minor 21 || (Plaintiffs), and Defendants Clark County School District (CCSD) and Kemala Washington 22 ||(Washington), collectively the “Moving Parties”, by and through their undersigned counsel, for 23 || good cause shown, hereby move the Court for an extension of time for Defendants CCSD and 24 || Washington to respond to Plaintiffs’ Complaint (ECF No. 1), up to and including February 26, 25 1/2024: 26 I. Defendants CCSD and Washington, Defendant Clark County Education 27 || Association (CCEA), and Defendant Lancaster jointly removed this action on February 9, 2024 28 1 ||(ECF No. 1), making February 16, 2024, the deadline for Defendants to answer or otherwise 2 ||respond to the Complaint. FRCP 81(c)(2)(C). 3 2. Defendants CCSD and Washington require additional time to respond to the 4 □□ Complaint. 5 3. On February 15, 2024, Defendant CCEA and Plaintiffs filed a similar Joint Motion 6 ||to Extend Deadline for Defendant CCEA to Respond to Complaint, agreeing to extend Defendant 7 ||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 9 || Washington to answer or otherwise respond to the Complaint by 10 days up to and including 10 || 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 4 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 1 CCSD’s and Defendant Washington’s deadline to answer or otherwise respond to the Complaint 24 (ECF No. 1) is extended up to and including February 26, 2024. 25 %6 IT IS SO ORDERED. gum la 57 ||DATED: _ 2/20/2024 . UNITED STATES MAGISTRATE JUDGE 28 I CERTIFICATE OF SERVICE 2 I HEREBY CERTIFY that on the | L day of February, 2024, I served the above and } 3 ||foregoing JOINT MOTION TO EXTEND DEADLINE FOR CLARK COUNTY SCHOOL 4 ||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 6 || Nevada (or if necessary, by electronic mail delivery and by U.S. Mail, first class, postage pre- 7 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 13 _ 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 20 21 22 23 24 25 26 27 28 Nan Langenderfer From: Colin Cavanaugh 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 ccavanaugh@thedplg.com | www.thedple.com From: Stephanie Barker Sent: Friday, February 16, 2024 3:05 PM To: Colin Cavanaugh Cc: Nan Langenderfer 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 sbarker@ocgas.com 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. 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