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Johnson v. James

United States District Court, D. Nevada

November 8, 2017

TANYA JOHNSON, Plaintiff,
v.
SECAF, DEBORAH LEE JAMES, Secretary of U.S. AIR FORCE; NELLIS AIR FORCE BASE, a Government Agency; NELLIS AFB, NEVADA, Defendants.

          STEVEN W. MYHRE Acting United States Attorney

          KRYSTAL J. ROSSE Assistant United States Attorney

          FEDERAL DEFENDANT'S MOTION TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         Pursuant 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.[1] In support of the instant Motion, Federal Defendant submits the following:

         1. Status Report.

         This 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.

         On 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.

         2. Status/Discovery Completed.

         Following 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.

         3. Discovery remaining.

         Plaintiffs responses to Federal Defendant's first set of interrogatories are due on November 27, 2017 and Federal Defendant intends to take Plaintiffs deposition.

         4. Reasons for extension.

         Federal 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.

         5. Revised discovery schedule. [2]

         Federal Defendant proposes the following revised discovery plan and respectfully requests that the Court adopt it as the ...


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