United States District Court District of Nevada (Las Vegas ... · PDF fileUnited States District Court District of Nevada (Las Vegas) CIVIL DOCKET FOR CASE #:...

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United States District CourtDistrict of Nevada (Las Vegas)

CIVIL DOCKET FOR CASE #: 2:15cv00388JADPAL

Roberts v. Clark County School DistrictAssigned to: Judge Jennifer A. DorseyReferred to: Magistrate Judge Peggy A. LeenCase in other court: District Court, Clark County, Nevada, A

14708620CCause: 42:2000e Job Discrimination (Employment)

Date Filed: 03/04/2015Jury Demand: PlaintiffNature of Suit: 442 Civil Rights: JobsJurisdiction: Federal Question

PlaintiffBradley Roberts represented by Jason Maier

Maier Gutierrez Ayon 400 South Seventh Street Suite 400 Las Vegas, NV 89101 702.629.7900 Fax: 702.629.7925 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Kathleen J England England Law Office 630 S. Third Street Las Vegas, NV 89101 7023853300 Fax: 7023853823 Email: [email protected] ATTORNEY ATTORNEY TO BE NOTICED

Margaret A McLetchie McLetchie Shell LLC 701 East Bridger Ave., Suite 520 Las Vegas, NV 89101 (702) 7285300 Fax: (702)4258220 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Danielle J. Barraza Maier Gutierrez Ayon 400 South Seventh Street Suite 400 Las Vegas, NV 89101



7026297900 Fax: 7026297925 Email: [email protected]

ATTORNEY TO BE NOTICED

V.DefendantClark County School District represented by Bruce C Young

Littler Mendelson, PC 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 891695937 7028628800 Fax: 7028628811 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Ethan Thomas Littler Mendelson 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89169 702.862.8800 Fax: 702.862.8811 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Patrick H. Hicks Littler Mendelson, PC 3960 Howard Hughes Parkway Suite 300 Las Vegas, NV 89109 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed # Docket Text

03/04/2015 1 PETITION FOR REMOVAL from District Court, Clark County, Nevada, CaseNumber A14708620C, (Filing fee $ 400 receipt number 09783579382), filedby Clark County School District. Certificate of Interested Parties due by3/14/2015. (Attachments: # 1 Civil Cover Sheet Civil Cover Sheet, # 2 Exhibit 13) (Thomas, Ethan) (Entered: 03/04/2015)

03/04/2015 Case assigned to Judge Jennifer A. Dorsey and Magistrate Judge Peggy A. Leen.(EDS) (Entered: 03/04/2015)

https://ecf.nvd.uscourts.gov/cgi-bin/show_doc.pl?add_padlock=0&caseid=106584&de_seq_num=9&dm_id=7016973&doc_num=1&pdf_header=2

https://ecf.nvd.uscourts.gov/doc1/11515173599




03/04/2015 CASE REFERRED to Early Neutral Evaluation Program. Magistrate JudgeGeorge Foley, Jr will be the evaluating judge in this case. (EDS) (Entered:03/04/2015)

03/04/2015 2 NOTICE PURSUANT TO LOCAL RULE IB 22: In accordance with 28 USC §636(c) and FRCP 73, the parties in this action are provided with a link to the "AO85 Notice of Availability, Consent, and Order of Reference Exercise ofJurisdiction by a U.S. Magistrate Judge" form on the Court's website www.nvd.uscourts.gov. AO 85 Consent forms should NOT be electronicallyfiled. Upon consent of all parties, counsel are advised to manually file the formwith the Clerk's Office. (A copy of form AO 85 has been mailed to parties notreceiving electronic service.)

NOTICE OF GENERAL ORDER 20131 AND OPPORTUNITY FOREXPEDITED TRIAL SETTING: The parties in this action are provided with alink to General Order 20131 and the USDC Short Trial Rules on the Court'swebsite www.nvd.uscourts.gov. If the parties agree that this action can be readyfor trial within 180 days and that a trial of this matter would take three (3) days orless, the parties should consider participation in the USDC Short Trial Program. Ifthe parties wish to be considered for entry into the Court's Short Trial Program,they should execute and electronically file with USDC Short Trial Form 4(a)(1) orForm 4(a)(2).

(no image attached) (EDS) (Entered: 03/04/2015)

03/04/2015 3 MINUTE ORDER IN CHAMBERS of the Honorable Judge Jennifer A. Dorsey,on 3/4/2015. Statement regarding removed action is due by 3/22/2015. JointStatus Report regarding removed action is due by 4/6/2015. (Copies have beendistributed pursuant to the NEF EDS) (Entered: 03/04/2015)

03/10/2015 4 STIPULATION FOR EXTENSION OF TIME (First Request) re 1 Petition forRemoval, ; by Defendant Clark County School District. (Thomas, Ethan)(Entered: 03/10/2015)

03/12/2015 5 ORDER ON STIPULATION granting 4 STIPULATION FOR EXTENSION OFTIME to file an answer to 1 complaint up to and including March 20, 2015.Signed by Magistrate Judge Peggy A. Leen on 3/12/2015. (Copies have beendistributed pursuant to the NEF DKJ) (Entered: 03/13/2015)

03/13/2015 6 CERTIFICATE of Interested Parties filed by Clark County School District. Thereare no known interested parties other than those participating in the case .(Thomas, Ethan) (Entered: 03/13/2015)

03/16/2015 7 DEMAND for Trial by Jury by Plaintiff Bradley Roberts . (England, Kathleen)(Entered: 03/16/2015)

03/18/2015 8 STATEMENT RE: REMOVAL filed by Defendant Clark County School District.(Young, Bruce) (Entered: 03/18/2015)

03/20/2015 9 MOTION to Dismiss by Defendant Clark County School District. Responses dueby 4/6/2015. (Attachments: # 1 Exhibit 14)(Young, Bruce) (Entered: 03/20/2015)

03/20/2015 10 ORDER for Certificate of Interested Parties. IT IS ORDERED that Plaintiff shallfile his Certificate of Interested Parties by 4:00 p.m., 4/3/2015. Failure to comply

http://www.nvd.uscourts.gov/Files/AO_085_0109.pdf

http://www.nvd.uscourts.gov/Files/USDC_Short_Trial_Rules_and_forms.pdf















may result in the issuance of an order to show cause why sanctions should not beimposed. Signed by Magistrate Judge Peggy A. Leen on 3/20/2015. (Copies havebeen distributed pursuant to the NEF SLD) (Entered: 03/23/2015)

03/23/2015 11 CERTIFICATE of Interested Parties filed by Bradley Roberts. There are noknown interested parties other than those participating in the case . (England,Kathleen) (Entered: 03/23/2015)

03/23/2015 12 ORDER Scheduling Early Neutral Evaluation Session. Early Neutral Evaluationset for 5/28/2015 09:00 AM in LV Chambers before Magistrate Judge GeorgeFoley Jr. Signed by Magistrate Judge George Foley, Jr on 3/23/2015. (Copieshave been distributed pursuant to the NEF DC) (Entered: 03/23/2015)

04/02/2015 13 STIPULATION FOR EXTENSION OF TIME (First Request) for Opposition toDefendant's Motion to Dismiss by Plaintiff Bradley Roberts. (England, Kathleen)(Entered: 04/02/2015)

04/06/2015 14 STATUS REPORT RE: REMOVAL filed by Defendant Clark County SchoolDistrict, Plaintiff Bradley Roberts. (Young, Bruce) (Entered: 04/06/2015)

04/06/2015 15 ORDER granting 13 Stipulation to extend time to respond to 9 motion to dismiss.Responses due by 4/30/2015. Signed by Judge Jennifer A. Dorsey on 4/6/2015.(Copies have been distributed pursuant to the NEF DKJ) (Entered: 04/06/2015)

04/20/2015 16 PROPOSED Discovery Plan/Scheduling Order filed by Defendant Clark CountySchool District . (Young, Bruce) Corrected Image 17 filed on 4/20/15. (ASB)(Entered: 04/20/2015)

04/20/2015 17 NOTICE of Corrected Image/Document re 16 Proposed DiscoveryPlan/Scheduling Order by Defendant Clark County School District. (Service ofcorrected image is attached). (Young, Bruce) (Entered: 04/20/2015)

04/21/2015 18 PROPOSED Discovery Plan/Scheduling Order filed by Plaintiff Bradley Roberts .(Maier, Jason) (Entered: 04/21/2015)

04/21/2015 19 NOTICE of Hearing: A Scheduling Conference is set for 4/28/2015, at 10:30 AMin LV Courtroom 3C before Magistrate Judge Peggy A. Leen, regarding 16Defendant's Proposed Scheduling Order and Discovery Plan.(no image attached)(TKH) (Entered: 04/21/2015)

04/28/2015 20 MINUTES OF PROCEEDINGS Scheduling Conference held on 4/28/2015before Magistrate Judge Peggy A. Leen. Crtrm Administrator: Jeff Miller; PlaCounsel: Kathleen England, Esq.; Def Counsel: Bruce Young, Esq.; CourtReporter/FTR #: 10:32:18 10:52:10; Time of Hearing: 10:30am; Courtroom:3C; The Court has reviewed Counsels' competing Proposed Discovery Plan andScheduling Orders 16 and 18 , and hears the respective positions of Counsel. ITIS ORDERED: The Court will enter a 180 day Discovery Plan and SchedulingOrder, which will be measured from 4/14/2015. Both sides will be required tomake their Initial Disclosures by 5/01/2015. Plaintiff Counsel shall provide adetailed damages calculation as part of her Initial Disclosures. Parties shall berequired to produce the documents requested as articulated in Plaintiff Counsel'sproposal with the exception of attorney/client privileged materials. (no imageattached) (Copies have been distributed pursuant to the NEF JAM) (Entered:04/28/2015)


















04/30/2015 21 SECOND STIPULATION FOR EXTENSION OF TIME to File Opposition; filedby Plaintiff Bradley Roberts. (Maier, Jason) (Entered: 04/30/2015)

04/30/2015 22 ORDER granting 21 Stipulation to extend the response deadline to 9 motion todismiss to May 7, 2015. Signed by Judge Jennifer A. Dorsey on 4/30/2015.(Copies have been distributed pursuant to the NEF DKJ) (Entered: 05/01/2015)

05/06/2015 23 ORDER. Discovery due by 10/12/2015. Motions due by 11/10/2015. ProposedJoint Pretrial Order due by 12/10/2015. Signed by Magistrate Judge Peggy A.Leen on 5/6/2015. (Copies have been distributed pursuant to the NEF DKJ)(Entered: 05/06/2015)

05/08/2015 24 THIRD Stipulation for Extension of time to File response filed by PlaintiffBradley Roberts. (Maier, Jason) (Entered: 05/08/2015)

05/11/2015 25 ORDER granting 24 Stipulation to extend time to respond to 9 motion to dismiss.Responses due by 5/13/2015. Signed by Judge Jennifer A. Dorsey on 5/11/2015.(Copies have been distributed pursuant to the NEF DKJ) (Entered: 05/11/2015)

05/13/2015 26 RESPONSE to 9 Motion to Dismiss, filed by Plaintiff Bradley Roberts. Repliesdue by 5/23/2015. (England, Kathleen) (Entered: 05/13/2015)

05/13/2015 27 APPENDIX 1 to 26 RESPONSE to 9 Motion to Dismiss; filed by PlaintiffBradley Roberts. (England, Kathleen) Wrong event selected, event modifiedand docket entry relationship established on 5/14/2015 (RFJ). (Entered:05/13/2015)

05/13/2015 28 APPENDIX 2 JS to 26 Response to Motion ; filed by Plaintiff Bradley Roberts.(England, Kathleen) (Entered: 05/13/2015)

05/14/2015 NOTICE of Docket Correction to 27 Reply to Response to Motion:

ERROR: Wrong event selected by attorney Kathleen J England.

CORRECTION: Court corrected the event to APPENDIX 1 to 26 RESPONSE to9 Motion to Dismiss. (no image attached)(RFJ) (Entered: 05/14/2015)

05/21/2015 29 STIPULATION FOR EXTENSION OF TIME (First Request) re 9 Motion toDismiss ; by Defendant Clark County School District. (Thomas, Ethan) (Entered:05/21/2015)

05/21/2015 30 ORDER granting 29 Stipulation to extend time to file a reply to 9 Motion toDismiss to June 12, 2015. Signed by Judge Jennifer A. Dorsey on 5/21/2015.(Copies have been distributed pursuant to the NEF DKJ) (Entered: 05/21/2015)

06/02/2015 31 MINUTES OF PROCEEDINGS Early Neutral Evaluation Conference held on6/2/2015 before Magistrate Judge George Foley, Jr. Judicial Assistant: JuliaWright; Pla Counsel: Kathleen England and Maggie McLetchie; Def Counsel:Ethan Thomas and Bruce Young; Time of Hearing: 9:00 a.m.

The court heard presentations from counsel and from each of the parties present.No settlement was reached; however, counsel advised that continuation of theENE session could advance the goal of settlement. See attached Minutes.

Early Neutral Evaluation set for Friday, June 19, 2015, at 9:00 AM in LV



























Chambers before Magistrate Judge George Foley Jr. (Copies have been distributedpursuant to the NEF JBW) (Entered: 06/02/2015)

06/11/2015 32 SECOND STIPULATION FOR EXTENSION OF TIME to File Reply; filed byDefendant Clark County School District. (Thomas, Ethan) (Entered: 06/11/2015)

06/11/2015 33 MOTION for Leave to File Supplement; filed by Plaintiff Bradley Roberts.(Attachments: # 1 Exhibit)(England, Kathleen) (Entered: 06/11/2015)

06/11/2015 34 ORDER ON STIPULATION Granting 32 SECOND STIPULATION FOREXTENSION OF TIME to File Reply re 9 MOTION to Dismiss. Replies due by6/30/2015. Signed by Judge Jennifer A. Dorsey on 6/11/15. (Copies have beendistributed pursuant to the NEF MMM) (Entered: 06/12/2015)

06/18/2015 35 RESPONSE to 33 Motion for Leave to File, filed by Defendant Clark CountySchool District. Replies due by 6/28/2015. (Attachments: # 1 Exhibit 18)(Thomas, Ethan) (Entered: 06/18/2015)

06/19/2015 36 MINUTES OF PROCEEDINGS Early Neutral Evaluation Conference held on6/19/2015 before Magistrate Judge George Foley, Jr. Judicial Assistant: JuliaWright; Pla Counsel: Kathleen England and Maggie McLetchie; Def Counsel:Bruce Young; Time of Hearing: 9:00 a.m.

The court heard presentations from counsel and from each of the parties present.No settlement was reached. This case should be returned to the normal litigationtrack. See attached Minutes. (Copies have been distributed pursuant to the NEF JBW) (Entered: 06/19/2015)

06/29/2015 37 MINUTE ORDER IN CHAMBERS of the Honorable Judge Jennifer A. Dorsey,on 6/29/2015. By Judicial Assistant: Cathy Stuchell. Re: 33 Motion for Leave toFile Supplement in Support of Opposition to Motion to Dismiss. Pending beforethe court is defendant's motion to dismiss 9 . Plaintiff filed a response 26 to themotion and then moved to supplement that response with additional evidence 33 .Defendant opposes the request to supplement 35 , but has not yet filed its reply.Good cause appearing, and as any prejudice to the defendant can be eliminated byenlarging its time for response, IT IS HEREBY ORDERED that the motion forleave to file a supplement 33 is GRANTED so that the court can have all relevantarguments and information before it when deciding the motion to dismiss. Thecourt reserves for a later date the question of whether the supplementalinformation will be considered. Defendant will have until July 10, 2015, to file itsreply in support of the motion to dismiss 9 .(no image attached) (Copies havebeen distributed pursuant to the NEF CS) (Entered: 06/29/2015)

06/30/2015 38 NOTICE of Hearing on 9 Defendant's Motion to Dismiss Plaintiff's FirstAmended Complaint: Motion Hearing set for 9/14/2015 at 10:30 AM in LVCourtroom 6D before Judge Jennifer A. Dorsey. (no image attached)(DMS)(Entered: 06/30/2015)

07/03/2015 39 NOTICE of Change of Law Firm Affiliation filed by Bradley Roberts.(McLetchie, Margaret) (Entered: 07/03/2015)

07/09/2015 40 MOTION for Leave to File Excess Pages by Defendant Clark County SchoolDistrict. (Thomas, Ethan) (Entered: 07/09/2015)























07/10/2015 41 REPLY to Response to 9 Motion to Dismiss filed by Defendant Clark CountySchool District. (Young, Bruce) (Entered: 07/10/2015)

07/17/2015 42 ORDER. Good cause appearing, Defendant's Motion for Order to Exceed 20PageLimitation on Length of Reply in Support of its Motion to Dismiss 40 isGRANTED. The parties shall appear for a hearing on Defendant's Motion toDismiss Plaintiff's First Amended Complaint 9 on August 31, 2015, at 9:00 a.m.Oral argument will be limited to 20 minutes per side. Signed by Judge Jennifer A.Dorsey on 7/17/2015. (Copies have been distributed pursuant to the NEF DMS)(Entered: 07/17/2015)

07/17/2015 43 MINUTE ORDER IN CHAMBERS of the Honorable Judge Jennifer A. Dorsey,on 7/17/2015. By Deputy Clerk: D. Sherwood. IT IS ORDERED the hearing onDefendant's Motion to Dismiss Plaintiff's First Amended Complaint 9 set on9/14/2015 at 10:30 AM is hereby VACATED. The previous Order 42 setting thehearing on August 31, 2015, at 9:00 a.m. is the correct date and time. (no imageattached) (Copies have been distributed pursuant to the NEF DMS) (Entered:07/17/2015)

07/30/2015 44 STIPULATION for Protective Order; filed by Plaintiff Bradley Roberts.(England, Kathleen) (Entered: 07/30/2015)

07/31/2015 45 ORDER Granting 44 Stipulated Protective Order. Signed by Magistrate JudgePeggy A. Leen on 7/31/15. (Copies have been distributed pursuant to the NEF PS) (Entered: 08/03/2015)

08/03/2015 46 NOTICE of Change of Address by Margaret A McLetchie. (McLetchie, Margaret)(Entered: 08/03/2015)

08/07/2015 47 STIPULATION FOR EXTENSION OF TIME (First Request) re Discovery byPlaintiff Bradley Roberts. (England, Kathleen) (Entered: 08/07/2015)

08/10/2015 48 SCHEDULING ORDER Granting 47 Stipulation to Extend Discovery Deadline.Discovery due by 12/11/2015. Motions due by 1/11/2016. Proposed Joint PretrialOrder due by 2/10/2016. Signed by Magistrate Judge Peggy A. Leen on 8/10/15.(Copies have been distributed pursuant to the NEF TR) (Entered: 08/11/2015)

08/31/2015 49 MINUTES OF PROCEEDINGS Motion Hearing held on 8/31/2015 beforeJudge Jennifer A. Dorsey. Crtrm Administrator: D. Sherwood; Pla Counsel:Kathleen England, Margaret McLetchie; Def Counsel: Bruce Young; CourtReporter/FTR #: Felicia Zabin; Time of Hearing: 9:00 a.m.11:10 a.m.;Courtroom: 6D; The Court hears the arguments of Mr. Young and Ms. England.The Court places detailed findings of fact and conclusions of law on the recordand finds as follows: IT IS ORDERED 9 Defendant's Motion to DismissPlaintiff's First Amended Complaint is GRANTED as to Plaintiff's 4th cause ofaction and DENIED as to Plaintiff's 1st, 2nd and 3rd causes of action. Thedismissal of Plaintiff's 4th cause of action is without leave to amend. Thetranscript of these proceedings shall serve as the Court's formal Order. (Copieshave been distributed pursuant to the NEF DMS) (Entered: 08/31/2015)

09/11/2015 50 ANSWER to Complaint re 1 Petition for Removal, filed by Clark County SchoolDistrict. Certificate of Interested Parties due by 9/21/2015. DiscoveryPlan/Scheduling Order due by 10/26/2015.(Thomas, Ethan) (Entered: 09/11/2015)


















10/01/2015 51 Interim STATUS REPORT by Defendant Clark County School District. (Thomas,Ethan) (Entered: 10/01/2015)

10/21/2015 52 MOTION to Compel Rule 34 Inspection of Original CCSD Documents byPlaintiff Bradley Roberts. Responses due by 11/7/2015. (Attachments: # 1 Exhibit1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7Exhibit 7)(England, Kathleen) (Entered: 10/21/2015)

10/27/2015 53 MOTION for Leave to File Excess Pages for Motion for Partial SummaryJudgment by Plaintiff Bradley Roberts. (Attachments: # 1 Exhibit)(Maier, Jason)(Entered: 10/27/2015)

10/27/2015 54 MOTION for Partial Summary Judgment by Plaintiff Bradley Roberts. Responsesdue by 11/20/2015. (Maier, Jason) (Entered: 10/27/2015)

10/27/2015 55 APPENDIX 1 of Exhibits for 54 Plaintiff's Motion for Partial Summary Judgment(Exhibits 125) filed by Plaintiff Bradley Roberts. (Attachments: # 1 Exhibit, # 2Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit,# 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, #15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, #21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit)(Maier, Jason)(Entered: 10/27/2015)

10/27/2015 56 APPENDIX 2 of Exhibits for 54 Plaintiff's Motion for Partial Summary Judgment(Exhibits 2648, 5054) filed by Plaintiff Bradley Roberts. (Attachments: # 1Exhibit 26, # 2 Exhibit 27, # 3 Exhibit 28, # 4 Exhibit 29, # 5 Exhibit 30, # 6Exhibit 31, # 7 Exhibit 32, # 8 Exhibit 33, # 9 Exhibit 34, # 10 Exhibit 35, # 11Exhibit 36, # 12 Exhibit 37, # 13 Exhibit 38, # 14 Exhibit 39, # 15 Exhibit 40, #16 Exhibit 41, # 17 Exhibit 42, # 18 Exhibit 43, # 19 Exhibit 44, # 20 Exhibit 45,# 21 Exhibit 46, # 22 Exhibit 47, # 23 Exhibit 48, # 24 Exhibit 49, # 25 Exhibit50, # 26 Exhibit 51, # 27 Exhibit 52, # 28 Exhibit 53, # 29 Exhibit 54)(Maier,Jason) (Entered: 10/27/2015)

10/30/2015 57 MOTION to Compel by Defendant Clark County School District. Responses dueby 11/16/2015. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9,# 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit14, # 15 Exhibit 16)(Thomas, Ethan) (Entered: 10/30/2015)

10/30/2015 58 MOTION to Seal by Defendant Clark County School District. (Thomas, Ethan)(Entered: 10/30/2015)

10/30/2015 60 MOTION for Protective Order by Defendant Clark County School District. (DKJ)(Entered: 11/02/2015)

11/02/2015 NOTICE of Docket Correction to to 57 Motion to Compel: ERROR:Documents should have been filed as separate entries by attorney, ETHANTHOMAS . In accordance with Special Order 109, a separate document must befiled for each type of document or purpose . Counsel advised in the future pleasefile documents in accordance with Special Order 109 filing procedures to preventdelay in the timely filing of documents. CORRECTION: Court docketed theMOTION TO COMPEL contained within document 57 as 60 MOTION FORPROTECTIVE ORDER. (no image attached)(DKJ) (Entered: 11/02/2015)






























































































11/09/2015 61 RESPONSE to 52 Motion to Compel, filed by Defendant Clark County SchoolDistrict. Replies due by 11/19/2015. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, #3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7)(Thomas,Ethan) (Entered: 11/09/2015)

11/12/2015 62 NOTICE of Hearing on 52 MOTION to Compel Rule 34 Inspection of OriginalCCSD Documents, 57 MOTION to Compel , 58 MOTION to Seal , and 60MOTION for Protective Order : Motion Hearing set for 12/8/2015, at 9:45 AM inLV Courtroom 3B before Magistrate Judge Peggy A. Leen. (no image attached)(TKH) (Entered: 11/12/2015)

11/13/2015 63 STIPULATION FOR EXTENSION OF TIME (Second Request) re 48Scheduling Order, ; by Defendant Clark County School District. (Thomas, Ethan)(Entered: 11/13/2015)

11/13/2015 64 STIPULATION FOR EXTENSION OF TIME (First Request) re 54 Motion forPartial Summary Judgment ; by Defendant Clark County School District.(Thomas, Ethan) (Entered: 11/13/2015)

11/13/2015 65 STIPULATION FOR EXTENSION OF TIME (First Request) re 52 Motion toCompel; 57 Motion to Compel and 60 Qualified Protective Order by PlaintiffBradley Roberts. (England, Kathleen) Docket text relationship modified on11/16/2015 (DKJ). (Entered: 11/13/2015)

11/16/2015 66 ORDER Granting 64 Stipulation to Extend Time re 54 MOTION for PartialSummary Judgment Plaintiff Bradley Roberts' Motion for Partial SummaryJudgment. Responses due by 12/4/2015. Signed by Judge Jennifer A. Dorsey on11/16/15. (Copies have been distributed pursuant to the NEF TR) (MainDocument 66 replaced on 11/16/2015) (TR). (Entered: 11/16/2015)

11/16/2015 67 SCHEDULING ORDER Granting 63 Stipulation to Extend Discovery. Discoverydue by 2/19/2016. Motions due by 3/21/2016. Proposed Joint Pretrial Order dueby 4/20/2016. Signed by Magistrate Judge Peggy A. Leen on 11/16/15. (Copieshave been distributed pursuant to the NEF TR) (Entered: 11/16/2015)

11/16/2015 68 ORDER Granting 65 Stipulation to Extend Deadlines. Replies due by 11/23/2015re 52 MOTION to Compel. Responses due by 11/19/2015 re 57 MOTION toCompel and 60 MOTION for Protective Order. Signed by Magistrate Judge PeggyA. Leen on 11/16/15. (Copies have been distributed pursuant to the NEF TR)(Entered: 11/16/2015)

11/19/2015 69 STIPULATION FOR EXTENSION OF TIME (Second Request) re 57 Motion toCompel Discovery Responses and 60 Motion for Qualified Protective Order byPlaintiff Bradley Roberts. (Maier, Jason) Docket entry relationship added on11/20/2015 (DKJ). (Entered: 11/19/2015)

11/19/2015 70 NOTICE of Agreement to Defendant's Motion to File Their Exhibit 15 Under Sealre 57 Motion to Compel by Bradley Roberts. (Maier, Jason) (Entered:11/19/2015)

11/20/2015 71 NOTICE: Attorney Action Required. PURSUANT TO LR IA 101 In order topractice before the United States District Court an attorney must be admitted tothe bar of this court. According to the Courts records attorney DANIELLE J.BARRAZA is not a member of the U.S. District Court, District of Nevada and is







































required to comply with LR IA 101. Please visit the Courts website atwww.nvd.uscourts.gov for the Admission to Practice form. (no image attached)(DKJ) (Entered: 11/20/2015)

11/20/2015 72 STIPULATION FOR EXTENSION OF TIME (Second Request) re 57 Motion toCompel Discovery Responses and 60 Motion for Qualified Protective Order byPlaintiff Bradley Roberts. (Maier, Jason) Modified docket entry relationship on11/20/2015 (DKJ). (Entered: 11/20/2015)

11/20/2015 73 NOTICE of Agreement to Defendant's Motion to File Their Exhibit 15 Under Sealre 57 Motion to Compel, by Bradley Roberts. (Maier, Jason) Docket entryrelationship on 11/20/2015 (DKJ). (Entered: 11/20/2015)

11/20/2015 74 ORDER Granting 72 Stipulation to Extend Deadlines re 57 Motion to Compel and60 Motion for Qualified Protective Order. Responses due by 11/20/2015. Signedby Magistrate Judge Peggy A. Leen on 11/20/15. (Copies have been distributedpursuant to the NEF TR) (Entered: 11/20/2015)

11/20/2015 75 RESPONSE to 60 Motion for Protective Order, filed by Plaintiff Bradley Roberts.Replies due by 11/30/2015. (Attachments: # 1 Exhibit A)(Maier, Jason) (Entered:11/20/2015)

11/20/2015 76 RESPONSE to 57 Motion to Compel, filed by Plaintiff Bradley Roberts. Repliesdue by 11/30/2015. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H)(Maier,Jason) (Entered: 11/20/2015)

11/23/2015 77 REPLY to Response to 52 Motion to Compel, filed by Plaintiff Bradley Roberts.(Attachments: # 1 Exhibit 8, # 2 Exhibit 9, # 3 Exhibit 10, # 4 Exhibit 11, # 5Exhibit 12)(England, Kathleen) (Entered: 11/23/2015)

11/24/2015 78 STIPULATION FOR EXTENSION OF TIME (First Request) re 57 Motion toCompel, 60 Motion for Protective Order ; by Defendant Clark County SchoolDistrict. (Thomas, Ethan) (Entered: 11/24/2015)

12/02/2015 79 REPLY to Response to 57 Motion to Compel, filed by Defendant Clark CountySchool District. (Attachments: # 1 Exhibit 18)(Thomas, Ethan) (Entered:12/02/2015)

12/02/2015 80 REPLY to Response to 60 Motion for Protective Order filed by Defendant ClarkCounty School District. (Attachments: # 1 Exhibit 18)(Thomas, Ethan) (Entered:12/02/2015)

12/02/2015 81 STIPULATION FOR EXTENSION OF TIME (Second Request) re 54 Motion forPartial Summary Judgment ; by Defendant Clark County School District.(Thomas, Ethan) (Entered: 12/02/2015)

12/02/2015 82 STIPULATION FOR EXTENSION OF TIME (Third Request) re 67 SchedulingOrder, ; by Defendant Clark County School District. (Thomas, Ethan) (Entered:12/02/2015)

12/03/2015 83 ORDER Granting 81 Stipulation to Extend Time for Defendant to File anOpposition to 54 Plaintiff's Motion for Partial Summary Judgment. Responses dueby 12/16/2015. Replies due by 1/6/2016. Signed by Judge Jennifer A. Dorsey on12/3/15. (Copies have been distributed pursuant to the NEF PS) (Entered:
















































12/03/2015)

12/03/2015 84 ORDER Granting 78 Stipulation to Extend Time re 57 MOTION to Compel and60 MOTION for Protective Order. Replies due by 12/3/2015. Signed byMagistrate Judge Peggy A. Leen on 12/3/15. (Copies have been distributedpursuant to the NEF TR) (Entered: 12/03/2015)

12/04/2015 85 ORDER ON STIPULATION Granting 82 Stipulation and Order to ExtendDiscovery (Third Request). Discovery due by 3/21/2016. Motions due by4/20/2016. Proposed Joint Pretrial Order due by 5/20/2016. Signed by MagistrateJudge Peggy A. Leen on 12/04/2015. (Copies have been distributed pursuant tothe NEF NEV) (Entered: 12/04/2015)

12/08/2015 86 MINUTES OF PROCEEDINGS Motion Hearing held on 12/8/2015 beforeMagistrate Judge Peggy A. Leen. Crtrm Administrator: Jeff Miller; Pla Counsel:Kathleen England, Esq.; Def Counsel: Bruce Young, Esq., Ethan Thomas, Esq.;Court Reporter/FTR #: 9:43:37 10:51:21; Time of Hearing: 9:45am; Courtroom:3B; The Court has reviewed Plaintiff's Motion to Compel 52 , Defendant's Motionto Compel 57 and Motion for Protective Order 60 , and Defendant's Motion toSeal 58 , as well as the related briefing. The Court hears the arguments ofCounsel. IT IS ORDERED: Plaintiff's Motion to Compel 52 is DENIED, IT ISORDERED: Defendant's Motion to Compel 57 and Motion for Protective Order60 is GRANTED in part and DENIED in part, IT IS ORDERED: Defendant'sMotion to Seal 58 is GRANTED. A separate written Order shall issue. (Copieshave been distributed pursuant to the NEF JAM) (Entered: 12/09/2015)

12/16/2015 87 MOTION for Leave to File Excess Pages by Defendant Clark County SchoolDistrict. (Thomas, Ethan) (Entered: 12/16/2015)

12/16/2015 88 RESPONSE to 54 Motion for Partial Summary Judgment, filed by DefendantClark County School District. Replies due by 12/26/2015. (Attachments: # 1Exhibit AH, # 2 Exhibit JP)(Thomas, Ethan) (Entered: 12/16/2015)

12/16/2015 89 Counter MOTION for Summary Judgment by Defendant Clark County SchoolDistrict. Responses due by 1/9/2016. (Attachments: # 1 Exhibit AH, # 2 ExhibitJP)(Thomas, Ethan) (Entered: 12/16/2015)

12/16/2015 90 MOTION to Seal by Defendant Clark County School District. (Thomas, Ethan)(Entered: 12/16/2015)

12/30/2015 92 STIPULATION FOR EXTENSION OF TIME (First Request) to File Oppositionto 89 Motion for Summary Judgment by Plaintiff Bradley Roberts. (Barraza,Danielle) (Entered: 12/30/2015)

12/31/2015 93 ORDER Granting 92 Stipulation to Extend Time re 89 Counter MOTION forSummary Judgment. Responses due by 1/29/2016. Signed by Judge Jennifer A.Dorsey on 12/31/15. (Copies have been distributed pursuant to the NEF TR)(Entered: 12/31/2015)

01/04/2016 94 RESPONSE to 90 Motion to Seal, filed by Plaintiff Bradley Roberts. Replies dueby 1/14/2016. (McLetchie, Margaret) (Entered: 01/04/2016)

01/04/2016 95 APPENDIX of Exhibits to 94 Response to Motion ; filed by Plaintiff BradleyRoberts. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3)(McLetchie,Margaret) (Entered: 01/04/2016)






































01/06/2016 96 SECOND STIPULATION FOR EXTENSION OF TIME re: 54 Plaintiff's Motionfor Partial Summary Judgment; filed by Plaintiff Bradley Roberts. (Barraza,Danielle) Modified docket entry relationship on 1/7/2016 (DKJ). (Entered:01/06/2016)

01/07/2016 97 ORDER Granting 96 Stipulation to Extend Time for Plaintiff to file a Reply insupport of 54 MOTION for Partial Summary Judgment Replies due by 1/6/2016.Signed by Judge Jennifer A. Dorsey on 1/7/16. (Copies have been distributedpursuant to the NEF PS) (Entered: 01/07/2016)

01/08/2016 98 REPLY to Response to 54 Motion for Partial Summary Judgment filed byPlaintiff Bradley Roberts. (Barraza, Danielle) (Entered: 01/08/2016)

01/11/2016 99 ORDER that 57 Motion to Compel is GRANTED in part and DENIED in partconsistent with this order. Plaintiff will be required to supplement discoveryresponses for which the motion was granted no later than January 25, 2016.Plaintiff will be precluded from supporting his claims with any evidence ortestimony not timely disclosed in motion practice, at trial, or for any otherpurpose. FURTHER ORDERED that 60 Motion for Protective Order is DENIED.The parties' requests for sanctions are denied. Any request for relief notspecifically addressed in this order is DENIED. Signed by Magistrate JudgePeggy A. Leen on 1/11/16. (Copies have been distributed pursuant to the NEF MMM) (Entered: 01/11/2016)

01/13/2016 100 STIPULATION FOR EXTENSION OF TIME (First Request) re 90 Motion toSeal ; by Defendant Clark County School District. (Thomas, Ethan) (Entered:01/13/2016)

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