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Jackson v. NYE County ex rel. NYE County Sherriff's Office

United States District Court, D. Nevada

November 13, 2017

KELLY JACKSON, an individual, Plaintiff,
v.
NYE COUNTY ex rel . NYE COUNTY SHERRIFF'S OFFICE; ANTONIO M. MEDINA Defendants.

          STIPULATION AND ORDER TO EXTEND DEADLINES SET FORTH IN JOINT DISCOVERY PLAN AND SCHEDULING ORDER (FIRST REQUEST)

         THE 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.

         This 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.

         A. STATEMENT SPECIFYING DISCOVERY COMPLETED (LR 26-4(a))

         The 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 9, 2017.

         On June 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.

         B. SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED (LR26-4 (b))

         Plaintiff 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.

         C. REASONS FOR REQUESTED EXTENSION (LR26-4 (c))

         The parties attended and participated in an ENE on July 27, 2017, but there was no settlement.

         Plaintiff 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.

         D. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY (LR26-4 (d))

         Pursuant to LR 26-4, the parties propose to extend the current deadlines and jointly submit the following to the Court:

         1. 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 21, 2018;

         2. 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 ...


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