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Doe v. Mazo

United States District Court, D. Nevada

May 3, 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.

          GREENBERG TRAURIG, LLP, MARK E. FERRARIO, ESQ. (NV BAR 1625) KARA B. HENDRICKS, ESQ. (NV BAR 7743) Attorneys for Defendant Clark County School District

          EGLET PRINCE, ROBERT T. EGLET, ESQ. (NV BAR 3402) ARTEMUS W. HAM, ESQ. (NV BAR 7001) AARON D. FORD, ESQ. (NV BAR 7704) Attorneys for Plaintiffs

          HALL JAFFE & CLAYTON, LLP, STEVEN T. JAFFE, ESQ. (NV BAR 7035) MICHELLE R. SCHWARZ, ESQ. (NV BAR5127) Attorneys for Defendant Clark County School District

          JOHN G. GEORGE, ESQ., JOHN G. GEORGE, ESQ. (NV BAR 12380) Counsel for Defendant Jeremiah Mazo

          [PROPOSED] AMENDED STIPULATION AND ORDER TO CONTINUE EXPERT WITNESS DEPOSITIONS AND DISPOSITIVE MOTION DEADLINES

         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 stipulate to an extension of expert witness depositions by thirty-two (32) days. The dispositive motion deadline will need to be extended accordingly. The parties therefore propose the following revised discovery plan for this Court's consideration.

         STIPULATION

         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 Requests for ...

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