United States District Court, D. Nevada
OFFICES OF STEVEN J. PARSONS JOSEPH N. MOTT Attorneys for
Plaintiff JESSE MOSLEY
RANALLI ZANIEL FOWLER & MORAN, LLC BENJAMIN J. CARMAN
Attorney for Defendant MERCURY CASUALTY COMPANY
PLAINTIFF AND DEFENDANT'S JOINT MOTION TO MODIFY
THE DISCOVERY PLAN AND SCHEDULING ORDER AND TO EXTEND THE
DISCOVERY DEADLINE AND OTHER DEADLINES SET FORTH
JESSE MOSLEY an individual, by his attorneys, Steven J.
Parsons and Joseph N. Mott of LAW OFFICES OF STEVEN J.
PARSONS, and MERCURY CASUALTY COMPANY, a California
corporation, by and through its attorney, BENJAMIN J. CARMAN
OF RANALLI ZANIEL FOWLER & MORAN, LLC, and, pursuant to
LR IA 6-1 and LR II 26-4, said Plaintiff and the Defendants
(comprising all of the parties hereto), hereby jointly move
this Court for an Order to Modify the most recent Order (Doc.
#15), which set forth this Court's Discovery Plan and
Scheduling Order (hereinafter the "Prior Scheduling
Order"), in order to allow the parties an additional
ninety (90) day extension beyond the current discovery
deadline of May 18, 2017, until August 16, 2017, to complete
discovery herein. Parties also hereby jointly move for an
additional ninety (90) day extension with respect to all
other dates set forth in the most recent Prior Scheduling
Order (Doc. #15) beyond the deadlines set forth therein.
Motion is filed for good cause shown as set forth below.
Certain of the requests herein are not made more than 21 days
before the expiration of any deadline sought to be extended
herein, as normally required by LR II 26-4 (namely the expert
disclosures deadline), but any such late submission is made
for good cause.
A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE
1. Defendant's Initial Disclosure, pursuant to FRCP
2. Plaintiff's Initial Disclosures, pursuant to FRCP
3. Defendant's First Set of Request for Admissions to
4. Defendant's First Set of Interrogatories to Plaintiff;
5. Defendant's First Set of Requests for Production of
Documents to Plaintiff;
6. Plaintiff's First Set of Request for Production of
Documents to Defendant;
7. Plaintiff's First Set of Interrogatories to Defendant;
8. Plaintiff's Second Set of Interrogatories to