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Doe v. Mazo

United States District Court, D. Nevada

February 23, 2018

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; Plaintiffs,
v.
JEREMIAH MAZO; CLARK COUNTY SCHOOL DISTRICT; DOES 1 through 20; DOE 1 through 20; ROE CORPORATIONS 1 through 20; Defendants.

          MARK E. FERRARIO, KARA B. HENDRICKS, GREENBERG TRAURIG, LLP., Counsel for Defendant Clark County School District.

          JOHN G. GEORGE, ESQ., Counsel for Defendant Jeremiah Mazo.

          [PROPOSED] AMENDED STIPULATION AND ORDER TO CONTINUE DISCOVERY

         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 agreement, Plaintiffs, JOHN and JANE DOE I, GUARDIANS AD LITEM FOR JOANN DOE I, A MINOR AND JOHN AND JANE DOE II, GUARDIANS AD LITEM FOR JOANN DOE II, A MINOR (collectively, “Plaintiffs”), Defendant CLARK COUNTY SCHOOL DISTRICT (“CCSD”) and Defendant JEREMIAH MAZO, by and through their respective counsel of record, hereby jointly submit this proposed amended stipulation extending certain case deadlines for the approval of the Court.[1]

         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:

Discovery Cut-Off Dated: 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 against all defendants. (Doc. 1). Plaintiffs filed a First Amended Class Action Complaint on March 1, 2017. (Doc. 39). CCSD filed its Answer to the First Amended Class Action Complaint on March 16, 2017, and asserted cross-claims against Defendant Mr. Mazo. (Doc. 43). Mr. Mazo filed an Answer to the Plaintiffs' First Amended Class Action Complaint on June 2, 2017 and his answer to CCSD's Cross-Claims on July 6, 2017 (Doc. Nos. 61, 67).

         II. Discovery Completed

         Plaintiffs have served Defendant Clark County School District with the following discovery to Dated:

         1. Plaintiffs' Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 10/10/2016;

         2. 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 First set of Request of Production of Documents served 10/27/16;

         3. Plaintiffs' First Supplement to Early Case Conference List of Documents and Witnesses Pursuant to FRCP 26(F) served 12/14/2016;

         4. 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;

         5. Plaintiff Joann Doe I's Responses to Clark County School District's First set of Interrogatories served 12/14/2016; 6. 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;

         7. 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 served 12/14/2016;

         8. 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;

         9. Plaintiff Joann Doe II's Responses to Clark County School District's First set of Interrogatories served 12/14/2016;

         10. 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;

         11. 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. 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;

         14. Plaintiff Jane Doe I, as Guardian ad Litem for Joann Doe I, a minor's First set of Interrogatories served 01/18/2017;

         15. Plaintiff John Doe I, as Guardian ad Litem for Joann Doe I, a minor's First set of Interrogatories served 01/18/2017;

         16. 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;

         17. 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 ...


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