J.L. et al v. Clark County School District et al, No. 2:2023cv00810 - Document 35 (D. Nev. 2024)

Court Description: ORDER granting 34 Stipulation to Modify Scheduling Order. Discovery Plan and Scheduling Order. Discovery due by 7/8/2024. Motions due by 11/5/2024. Proposed Joint Pretrial Order due by 12/5/2024. Signed by Magistrate Judge Brenda Weksler on 3/18/2024. (Copies have been distributed pursuant to the NEF - CAH)

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J.L. et al v. Clark County School District et al Doc. 35 1 RAHUL RAVIPUDI, ESQ., NV Bar No. 14750 rravipudi@psbr.law 2 IAN SAMSON, ESQ., NV Bar No. 15089 isamson@psbr.law 3 ADAM ELLIS, ESQ., NV Bar No. 14514 aellis@psbr.law 4 JULIA ARMENDARIZ, ESQ. NV Bar No. 15865 jarmendariz@psbr.law 5 PANISH |SHEA | BOYLE | RAVIPUDI LLP 300 South Fourth Street, Suite 710 6 Las Vegas, Nevada 89101 Tel: (702) 560-5520 7 Fax: (702) 975-2515 8 KHALDOUN A. BAGHDADI, ESQ., CA Bar No. 190111 kbaghdadi@walkuplawoffice.com 9 VALERIE N. ROSE, ESQ., CA Bar No. 272566 vrose@walkuplawoffice.com 10 KATHERINE CONNOLLY, ESQ., CA Bar No. 343524 kconnolly@walkuplawoffice.com 11 WALKUP, MELODIA, KELLY & SCHOENBERGER 650 California Street, 26th Floor 12 San Francisco, CA 94108-2615 Tel: (415) 981-7210 13 Fax: (415) 391-6965 (Admitted Pro Hac Vice) 14 15 ATTORNEYS FOR PLAINTIFFS 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA, SOUTHERN DIVISION 18 19 J.L., a minor by and through his Guardian Ad Litem MINA LILLY, T.A., 20 a minor by and through her Guardian Ad Litem SHWANA HARDY; and S.T., a 21 minor by and through his Guardian Ad Litem JOANNE TAITANO, 22 Plaintiffs, 23 v. 24 CLARK COUNTY SCHOOL DISTRICT, 25 MELISSA OLSZEWSKI, SHAWN HALLAND and DOES 1-50, 26 Defendants. 27 Case No. 2:23-cv-00810-JCM-BNW STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER [SECOND REQUEST] District Judge James C. Mahan Magistrate Judge Brenda Weksler Date Filed: May 24, 2023 Trial Date: Unassigned 28 1 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW Dockets.Justia.com 1 2 3 The Parties, through their undersigned counsel, hereby stipulate as follows: 1. STATEMENT OF DISCOVERY COMPLETED The Parties submitted their stipulated discovery plan and scheduling order on 4 September 14, 2023 (Dkt. No. 25) and the Court entered its scheduling order on 5 September 15, 2023 (Dkt. No. 26). On December 29, 203, the Court granted the Parties’ 6 First Request to modify the scheduling order (Dkt. No. 33). The Parties have completed 7 the following discovery to date: 8 1. On September 28, 2023, Defendants Clark County School District 9 (“CCSD”) and Shawn Halland (collectively the “CCSD Defendants”) served their initial 10 disclosures. 11 2. On September 28, 2023, Plaintiffs served their initial disclosures. 12 3. On November 7, 2023, CCSD and Halland served their first supplemental 13 disclosures. 14 4. On November 22, 2023 CCSD served Interrogatories and Requests for 15 Production, Set One upon Plaintiffs J.L., T.A. and S.T. 16 5. On December 1, 2023, Plaintiffs served Interrogatories and Requests for 17 Production, Set One to Defendants CCSD and Halland. 18 6. On December 1, 2023, Plaintiffs noticed the depositions of Defendants 19 CCSD, Halland and Olszewski, as well as non-parties Daniel Ciarciaglini, Shirley 20 Diaz, Elaine Hansen, Natalie Holshue, James Kettner, Rebecca Lucero and Jodie 21 Swader. 22 7. On December 15, 2023, the CCSD Defendants requested dates for 23 depositions of Plaintiffs’ guardians. 24 8. On December 22, 2023, Plaintiffs served their responses to CCSD’s 25 Interrogatories and Requests for Production, Set One. 26 9. On January 16, 2024, CCSD served its responses to Plaintiffs’ 27 Interrogatories and Requests for Production, Set One. 28 LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 26TH FLOOR SAN FRANCISCO, CA 94108 (415) 981-7210 10. On January 19, 2024, CCSD and Halland served their second 2 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW 1 supplemental disclosures. 2 2. 3 STATEMENT COMPLETED 8 11 REMAINS TO BE 2. Additional depositions and written discovery, if needed based on information or evidence gathered through the outstanding discovery and pending depositions; 3. Disclosure of Experts, Expert Reports; and 9 10 THAT 1. Completion of all currently noticed depositions; 5 7 DISCOVERY The following discovery remains to be completed: 4 6 OF 4. Expert Discovery and Depositions. 3. REASONS WHY DISCOVERY WILL NOT BE COMPLETED BY THE CURRENT DISCOVERY CUTOFF Under the current deadlines, lay discovery closes on April 5, 2024. The Parties 12 13 need additional time to meet-and-confer regarding production of documents, to review 14 them when produced, and to take party depositions thereafter. The parties are also 15 engaged in ongoing settlement discussions and are hopeful that a resolution can be 16 reached. Accordingly, the Parties request a 90-day extension of all deadlines. 17 18 4. PROPOSED SCHEDULE The Parties hereby stipulate and agree that the deadlines to complete discovery 19 as set forth in the Scheduling Order (Dkt. No. 33) shall be extended ninety (90) days 20 as follows: 21 1. Lay Discovery Period: The deadline to complete lay discovery shall be 22 extended from April 5, 2024 to July 8, 2024. 23 2. Initial Expert Disclosure: The deadline to file initial expert reports 24 shall be extended from May 6, 2024 to August 5, 2024. 25 3. Rebuttal Expert Disclosure: The deadline to file rebuttal expert 26 reports shall be extended from June 5, 2024 to September 3, 2024. 27 4. Expert Discovery Period: The deadline to complete expert discovery 28 shall be extended from July 8, 2024 to October 7, 2024. LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 26TH FLOOR SAN FRANCISCO, CA 94108 (415) 981-7210 3 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW 1 5. Dispositive Motions: The deadline to file dispositive motions shall be 2 extended from August 7, 2024 to November 5, 2024. 3 6. Pretrial Order: If no dispositive motions are filed, the Joint Pretrial 4 Order shall be filed thirty (30) days after the date set for the filing of dispositive 5 motions. Therefore, the joint pretrial order shall be extended from September 6, 2024 6 to December 5, 2024. In the event dispositive motions are filed, the date for filing 7 the Joint Pretrial Order shall be suspended until thirty (30) days after the decision on 8 the dispositive motions or by further order of the court. 9 This stipulation and order is sought in good faith and not for the purpose of 10 delay. This is the second request for a scheduling extension. 11 IT IS SO STIPULATED. 12 13 Dated: March 15, 2024 W ALKUP , M ELODIA , K ELLY & S CHOENBERGER 14 By: 15 16 17 18 19 20 21 22 23 24 25 Dated: March 15, 2024 KHALDOUN A. BAGHDADI VALERIE N. ROSE KATHERINE CONNOLLY Attorneys for Plaintiffs Admitted Pro Hac Vice GREENBERG TRAURIG, LLP By: /s/ Kara Hendricks KARA B. HENDRICKS WHITNEY L. WELCH-KIRMSE Attorneys for Defendants CLARK COUNTY SCHOOL DISTRICT and SHAWN HALLAND 26 27 28 LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 26TH FLOOR SAN FRANCISCO, CA 94108 (415) 981-7210 4 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW 1 Dated: March 15, 2024 2 3 4 By /s/ Melissa Olszewski MELISSA OLSZEWSKI Pro Se 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 26TH FLOOR SAN FRANCISCO, CA 94108 (415) 981-7210 5 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW 1 2 ORDER In consideration of the stipulation by the Parties, and with good cause 3 appearing, 4 1. Lay Discovery Period: The deadline to complete lay discovery shall be 5 extended from April 5, 2024 to July 8, 2024. 6 2. Initial Expert Disclosure: The deadline to file initial expert reports 7 shall be extended from May 6, 2024 to August 5, 2024. 8 3. Rebuttal Expert Disclosure: The deadline to file rebuttal expert 9 reports shall be extended from June 5, 2024 to September 3, 2024. 10 4. Expert Discovery Period: The deadline to complete expert discovery 11 shall be extended from July 8, 2024 to October 7, 2024. 12 5. Dispositive Motions: The deadline to file dispositive motions shall be 13 extended from August 7, 2024 to November 5, 2024. 14 6. Pretrial Order: If no dispositive motions are filed, the Joint Pretrial 15 Order shall be filed thirty (30) days after the date set for the filing of dispositive 16 motions. Therefore, the joint pretrial order shall be extended from September 6, 2024 17 to December 5, 2024. In the event dispositive motions are filed, the date for filing the 18 Joint Pretrial Order shall be suspended until thirty (30) days after the decision on the 19 dispositive motions or by further order of the court. 20 21 22 23 24 25 IT IS SO ORDERED. UNITED STATES MAGISTRATE JUDGE March DATED this _____ 18 day of _____________, 2024. 26 27 28 LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET 26TH FLOOR SAN FRANCISCO, CA 94108 (415) 981-7210 6 STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER Case No. 2:23-cv-00810-JCM-BNW

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