United States District Court, D. Nevada
W. MYHRE Acting United States Attorney
KRYSTAL J. ROSSE Assistant United States Attorney
FEDERAL DEFENDANT'S MOTION TO EXTEND DISCOVERY
DEADLINES (FIRST REQUEST)
to Fed.R.Civ.P. 6(b) and LRIA 6-1, Federal Defendant, SECAF,
Deborah Lee James, Secretary of U.S. Air Force respectfully
requests an extension of time of remaining deadlines. This is
the first request to extend time to take discovery pursuant
to ECF No. 54. In support of the instant Motion, Federal
Defendant submits the following:
request is made more than 60 days before the current close of
discovery, which is currently set for January 18,
2018. Pursuant to Local Rules 6- 1(b) and 26-4, this
request is timely in that it is made before the discovery
cutoff. However, it is not timely in that it is made less
than 21 days before the deadline of the parties' interim
status report and Federal Defendant's expert disclosure
deadlines, which are set for November 16,
2017. Nonetheless, as set forth below, Federal
Defendant's request should still be approved because, as
discussed more fully below, this Motion is being filed nine
days before the deadline.
October 23, 2017, the Court held a hearing on Plaintiff Tanya
Johnson's counsel's motion to withdraw as counsel
(ECF No. 56). The Court granted the motion and gave Plaintiff
until November 27, 2017 to either retain new counsel or file
a notice of intent to proceed pro se. ECF No. 62. On
October 26, 2017, counsel for Federal Defendant emailed
Plaintiff (at the email address provided by former counsel)
regarding the upcoming deadline for the parties' interim
status report, suggesting the parties extend the deadlines by
sixty (60) days to account for the Court's order. On
October 30, 2017, counsel for Federal Defendant followed up
on her previous email. To date, Federal Defendant has not
received a response from Plaintiff.
the Court's order denying Federal Defendant's motion
to dismiss (ECF No. 52), on July 6, 2017, the parties held a
conference pursuant to Fed. R. Civ. P 26(f). The parties have
exchanged initial and supplemental disclosures. On July 21,
2017, the Court entered a Scheduling Order (ECF No. 54). On
September 29, 2017, counsel for Plaintiff filed a motion to
withdraw as counsel (ECF No. 56). On October 10, 2017,
Federal Defendant served its first set of interrogatories.
responses to Federal Defendant's first set of
interrogatories are due on November 27, 2017 and Federal
Defendant intends to take Plaintiffs deposition.
Reasons for extension.
Defendant requests this extension to allow Plaintiff to
determine how she will be proceeding in this case and allow
the parties adequate time to conduct and complete discovery.
This request is made in good faith and not for the purpose of
unnecessarily delaying the proceedings.
Revised discovery schedule. 
Defendant proposes the following revised discovery plan and
respectfully requests that the Court adopt it as the ...