John Doe I, et al., v. Jeremiah Mazo, et al.,, No. 2:2016cv00239 - Document 75 (D. Nev. 2018)
Court Description: ORDER Granting 73 Amended Stipulation to Continue Discovery. Discovery due by 5/29/2018. Motions due by 6/28/2018. Proposed Joint Pretrial Order due by 7/31/2018. Signed by Magistrate Judge Peggy A. Leen on 2/23/2018. (Copies have been distributed pursuant to the NEF - SLD)
Download PDF
<![CDATA[
John Doe I, et al., v. Jeremiah Mazo, et al., Doc. 75 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 1 of 8 Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) MARK E. FERRARIO Nevada Bar No. 1625 ferrariom@gtlaw.com KARA B. HENDRICKS Nevada Bar No. 7743 hendricksk@gtlaw.com GREENBERG TRAURIG, LLP 3773 Howard Hughes Parkway, Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Fax: (702) 792-9002 Counsel for Defendant Clark County School District UNITED STATES DISTRICT COURT DISTRICT OF NEVADA JOHN and JANE DOE I, Guardians Ad Litem for JOANN DOE I, a minor, individually and on behalf of all those similarly situated, and JOHN and JANE DOE II, Guardians Ad Litem for JOANN DOE II, a minor, individually and on behalf of all those similarly situated; vs. JEREMIAH MAZO; CLARK COUNTY SCHOOL DISTRICT; DOES 1 through 20; DOE 1 through 20; ROE CORPORATIONS 1 through 20; Plaintiffs, [PROPOSED] AMENDED STIPULATION AND ORDER TO CONTINUE DISCOVERY (Second Request) Defendants. Case No. 2:16-cv-00239-APG-PAL The parties have reached an agreement to attend mediation and to delay the limited remaining depositions in this case until after the mediation has taken place. In light of this MINOR AND JOHN AND JANE DOE II, GUARDIANS AD LITEM FOR JOANN DOE II, A agreement, Plaintiffs, JOHN and JANE DOE I, GUARDIANS AD LITEM FOR JOANN DOE I, A MINOR (collectively, “Plaintiffs”), Defendant CLARK COUNTY SCHOOL DISTRICT (“CCSD”) -1LV 421064659v1 Dockets.Justia.com Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 2 of 8 and Defendant JEREMIAH MAZO, by and through their respective counsel of record, hereby of the Court.1 jointly submit this proposed amended stipulation extending certain case deadlines for the approval STIPULATION Pursuant to Local Rule 6-1, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs, CCSD, and Jeremiah Mazo that the current deadlines be extended in the above referenced matter. The current deadlines are as follows: Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) Discovery Cut-Off Date: January 29, 2018 Dispositive Motions: February 28, 2018 Proposed Joint Pretrial Order: March 28, 2018 or 30 days after the Court rules on any dispositive motions. I. Background This case was filed on February 5, 2016, alleging abuse of students by a former CCSD teacher, Jeremiah Mazo, and bringing claims under Title IX against CCSD and state tort claims 1, 2017. (Doc. 39). CCSD filed its Answer to the First Amended Class Action Complaint on March Answer to the Plaintiffs’ First Amended Class Action Complaint on June 2, 2017 and his answer to against all defendants. (Doc. 1). Plaintiffs filed a First Amended Class Action Complaint on March 16, 2017, and asserted cross-claims against Defendant Mr. Mazo. (Doc. 43). Mr. Mazo filed an CCSD’s Cross-Claims on July 6, 2017 (Doc. Nos. 61, 67). II. discovery to date: Plaintiffs have served Defendant Clark County School District with the following Discovery Completed 1. Plaintiffs’ Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 10/10/2016; 1 The Parties submitted a stipulation to the Court in this regard on December 28, 2017 (Doc. 72) and are submitting this amendment due to the scheduling of the mediation for March 29, 2018 and basing the proposed new deadlines on the same. -2LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 3 of 8 2. Production of Documents served 10/27/16; 3. 4. 5. 6. 7. Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) Jane Doe II, Guardians ad Litem for Joann Doe II’s First set of Request of served 12/14/2016; 10. 11. Plaintiff Joann Doe II’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; Plaintiff John Doe II as Guardian ad Litem for Joann Doe II’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; Plaintiffs John and Jane Doe II as Guardians ad Litem for Joann Doe II’s Responses to Clark County School District’s First set of Request for Production of Documents served 12/14/2016; 12. Plaintiff Jane Doe II as Guardian ad Litem for Joann Doe II’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; Plaintiffs John and Jane Doe I as Guardians ad Litem for Joann Doe I’s Responses to Clark County School District’s First set of Request for Production of Documents 9. Plaintiff John Doe I as Guardian ad Litem for Joann Doe I’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; Plaintiff Joann Doe I’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; 8. Plaintiff Jane Doe I as Guardian ad Litem for Joann Doe I’s Responses to Clark County School District’s First set of Interrogatories served 12/14/2016; Plaintiffs’ First Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 12/14/2016; Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and Jane Doe II, Guardians ad Litem for Joann Doe II’s Second set of Requests for Production of Documents served 01/18/2017; 13. Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of Requests for Admission served 01/18/2017; -3- LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 4 of 8 14. 15. 16. 17. Interrogatories served 01/18/2017; Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) Production of Documents served 01/20/2017; 19. 20. 21. 22. 23. 24. 25. 26. 27. Plaintiffs John and Jane Doe I, Guardians ad Litem for Joann Doe I, and John and Jane Doe II, Guardians ad Litem for Joann Doe II’s Third set of Requests for 18. Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of Requests for Admission served 01/18/2017; Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of Interrogatories served 01/18/2017; Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a minor’s First set of Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor’s Second set of Interrogatories served 01/23/2017; Plaintiffs’ Second Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 02/10/17; Plaintiff Joann Doe II’s Supplemental Responses to CCSD’s First set of Interrogatories served on 03/01/17; Plaintiff Joann Doe I’s Supplemental Responses to CCSD’s First set of Interrogatories served on 03/01/17; Plaintiffs’ Third Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 05/31/17; Plaintiffs’ Fourth Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 07/07/17; Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Third Set of Interrogatories to CCSD served 07/11/17; Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Fourth Set of Interrogatories to CCSD served 08/22/17; Plaintiffs’ Fifth Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 10/11/17; Plaintiffs’ Expert Designation Pursuant to FRCP 26(A)(2) served 10/13/17. -4- LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 5 of 8 discovery to date: 1. CCSD’s Initial Disclosures served 10/05/2016; 2. CCSD’s First set of Interrogatories to Plaintiff Jane Doe I, as Guardian ad Litem for 3. CCSD’s First set of Interrogatories to Plaintiff Joann Doe I served 11/14/2016; 4. CCSD’s First set of Interrogatories to Plaintiff John Doe I, as Guardian ad Litem for 5. 6. 7. CCSD’s First set of Interrogatories to Plaintiff Joann Doe II served 11/14/2016; 8. CCSD’s First set of Interrogatories to Plaintiff John Doe II, as Guardian ad Litem for 9. 10. 11. CCSD’s First Supplemental Disclosures served 12/01/2016; 12. CCSD’s Second Supplemental Disclosures served 02/17/17; 13. CCSD’s Third Supplemental Disclosures served 02/24/17; 14. CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a 15. 16. Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) Defendant Clark County School District has served Plaintiffs with the following Joann Doe I served 11/14/2016; Joann Doe I served 11/14/2016; CCSD’s First set of Requests for Production of Documents to Plaintiffs John and Jane Doe I, as Guardians ad Litem for Joann Doe I served 11/14/2016; CCSD’s First set of Interrogatories to Plaintiff Jane Doe II, as Guardian ad Litem for Joann Doe II served 11/14/2016; Joann Doe II served 11/14/2016; CCSD’s First set of Requests for Production of Documents to Plaintiffs John and Jane Doe II, as Guardians ad Litem for Joann Doe II served 11/14/2016; CCSD’s Responses to Plaintiffs’ First set of Requests for Production of Documents to the Clark County School District served 12/01/2016; Minor’s First Set of Requests for Admission to CCSD served 02/24/17; CCSD’s Responses to Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s First Set of Requests for Admission to CCSD served 02/24/17; CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s First set of Interrogatories to CCSD served 02/27/17; -5LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 6 of 8 17. 18. 19. 20. 21. CCSD’s Fourth Supplemental Disclosures served 08/21/17; 22. CCSD’s Responses to Plaintiff Jon Doe I, as Guardian ad Litem for Joann Doe I, a 23. CCSD’s Sixth Supplemental Disclosures served 09/01/2017; 24. CCSD’s Seventh Supplemental Disclosures served 10/13/17; 25. CCSD’s Expert Witness Disclosures served 10/13/17. Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) CCSD’s Responses to Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s First set of Interrogatories to CCSD served 02/27/17; CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Second set of Interrogatories to CCSD served 03/10/17; CCSD’s Fourth Supplemental Disclosures Pursuant to FRCP 26(a)(1) and Pursuant to March 6, 2017 Order served 04/05/17; CCSD’s Responses to Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a Minor’s Third set of Interrogatories to CCSD served 07/24/17; Minor’s Fourth set of Interrogatories to CCSD served 09/21/17; The following depositions have been completed to date: 1. Ulandra Barnett 2. Ivy Burns 3. Sylvia Glass 4. Jennifer Mattiello 5. Nestor Mattiello 6. Jon Okazaki 7. Julia Pettit 8. Kristopher Pettit 9. Christine Prosen 10. Darrin Puana 11. Billie Rayford III. Discovery That Remains to be Completed 1. Deposition of Defendant Jeremy Mazo; -6- LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 7 of 8 2. Depositions of Plaintiffs Joann Doe I and Joann Doe II;2 and 3. Expert Depositions. IV. Basis for Extension The parties request this extension to allow the depositions of Joann Doe I, Joann Doe II, Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) Jeremy Mazo, and the parties’ expert witnesses to take place after a mediation, which the parties diligently engaged in discovery and believe that allowing these final depositions to take place extension to allow for the foregoing outstanding discovery to be completed after the anticipated have scheduled for March 29, 2018 with Bongiovi Dispute Resolutions, LLC. The parties have following the mediation will further mediation discussions. Accordingly, the parties request an completion of mediation which is scheduled for March 29, 2018 as detailed below. V. Proposed Modification Based on the foregoing, the parties jointly seek a modification of the current deadlines as follows: 1. Current Deadlines: Discovery Cut-Off Date: January 29, 2018 Dispositive Motions: February 28, 2018 Proposed Joint Pretrial Order: March 28, 2018 or 30 days after the Court rules on any dispositive motions. 2. Proposed Deadlines: Discovery Cut-Off Date: May 29, 2018 Dispositive Motions: June 28, 2018 Proposed Joint Pretrial Order: July 31, 2018 or 30 days after the Court rules on any dispositive motions. /// /// 2 Defendants have expressed a desire to conduct the depositions of Joann Doe I and Joann Doe II, who are both minors. Plaintiffs hereby reserve the right to object to such depositions from going forward. -7LV 421064659v1 Case 2:16-cv-00239-APG-PAL Document 73 Filed 02/22/18 Page 8 of 8 Greenberg Traurig, LLP 3773 Howard Hughes Parkway - Suite 400 North Las Vegas, Nevada 89169 (702) 792-3773 (702) 792-9002 (fax) 3. This request is made in good faith and not for the purposes of delay. IT IS SO STIPULATED. Dated this 22nd day of February, 2018. Dated this 22nd day of February, 2018. GREENBERG TRAURIG, LLP EGLET PRINCE /s/ Kara B. Hendricks MARK E. FERRARIO, ESQ. (NV BAR 1625) KARA B. HENDRICKS, ESQ. (NV BAR 7743) 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Attorneys for Defendant Clark County School District /s/ Artemus W. Ham ROBERT T. EGLET, ESQ. (NV BAR 3402) ARTEMUS W. HAM, ESQ. (NV BAR 7001) AARON D. FORD, ESQ. (NV BAR 7704) 400 S. 7th Street, 4th Floor Las Vegas, Nevada 89101 Attorneys for Plaintiffs Dated this 22nd day of February, 2018. Dated this 22nd day of February, 2018. HALL JAFFE & CLAYTON, LLP JOHN G. GEORGE, ESQ. /s/ Michelle R. Schwarz STEVEN T. JAFFE, ESQ. (NV BAR 7035) MICHELLE R. SCHWARZ, ESQ. (NV BAR 5127) 7425 Peak Drive Las Vegas, Nevada 89128 Attorneys for Defendant Clark County School District /s/ John G. George JOHN G. GEORGE, ESQ. (NV BAR 12380) 732 South Sixth Street, Suite 100 Las Vegas, Nevada 89101 Counsel for Defendant Jeremiah Mazo ORDER IT IS HEREBY ORDERED. DATED this 23rd day of February, 2018. ____________________________________________ UNITED STATES MAGISTRATE JUDGE -8LV 421064659v1
]]>
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You
should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.
