United States District Court, D. Nevada
STIPULATION AND ORDER TO EXTEND DEADLINES SET FORTH
IN JOINT DISCOVERY PLAN AND SCHEDULING ORDER (FIRST
PARTIES HEREBY STIPULATE AND AGREE by and between
Plaintiff KELLY JACKSON, by and through counsel Matthew Q.
Callister, Esq. and Mitchell S. Bisson, Esq., of the law firm
of Callister & Associates, and Defendant NYE COUNTY ex
rel. NYE COUNTY SHERRIFF'S OFFICE and ANTONIO MEDINA, by
and through counsel Rebecca Bruch, Esq., of the law firm of
Erickson, Thorpe & Swainston, LTD., that, in accordance
with LR 7-1 and 26-4 of the Local Rules of Practice for the
United States District Court, District of Nevada, the
Court's May 10, 2017 Discovery Plan and Scheduling (Doc
No. 22) be amended and deadlines as listed below be extended
ninety (90) days from the currently scheduled dates. This is
the first request to extend the deadlines by the parties.
request includes extensions of the deadlines for discovery,
initial expert and rebuttal expert disclosures under Rule
26(a)(2), dispositive motions, the interim status report, and
Joint Pretrial Order. The present and proposed new dates for
these deadlines are set forth in Section D below. The
extension is necessary to accommodate the completion of
certain depositions prior to retention of expert witnesses.
STATEMENT SPECIFYING DISCOVERY COMPLETED (LR
Rule 26(f) conference was held on April 19, 2017. Following
the Rule 26(f) conference, the proposed Joint Discovery Plan
and Scheduling Order was filed on May 2, 2017. The Court
approved the proposed Discovery Plan and Scheduling Order on
May 10, 2017. Defendant exchanged initial disclosures on July
18, 2017. Plaintiff exchanged initial disclosures on November
22, 2017, Defendant propounded Interrogatories upon
Plaintiff, which Plaintiff responded to. On July 31, 2017,
Defendant propounded Notice of Deposition upon Plaintiff
which was set for October 13, 2017. Plaintiff requested the
deposition to be vacated pursuant to Section C below.
SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE
COMPLETED (LR26-4 (b))
needs to propound written discovery and take numerous
depositions. Defendant needs to take the deposition of
Plaintiff and several others. Both parties need to retain
experts after the Plaintiff's deposition is taken and
depose the respective experts.
REASONS FOR REQUESTED EXTENSION (LR26-4 (c))
parties attended and participated in an ENE on July 27, 2017,
but there was no settlement.
was scheduled to appear for her deposition on October 13,
2017, however, the deposition was vacated due to
Plaintiff's traumatic experience at the Route 91 Harvest
Festival on October 1, 2017. At this time, Plaintiff is not
sure when she will be ready to proceed forward. Therefore,
this request is necessary to allow time for Plaintiff to heal
and prepare to move forward with discovery.
PROPOSED SCHEDULE FOR COMPLETING DISCOVERY (LR26-4
to LR 26-4, the parties propose to extend the current
deadlines and jointly submit the following to the Court:
Discovery Cut-Off Date: The current
deadline to complete discovery is December 20, 2017. The
parties propose extending the discovery deadline by 90 days,
which will make the new deadline to complete discovery March
Interim Status Report: The current
deadline to file a Joint Interim Status Report was October
23, 2017. The parties propose extending this deadline 90
days, which will ...