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Richards v. Cox

United States District Court, D. Nevada

November 28, 2017

STACEY M. RICHARDS, Plaintiff,
v.
GREG COX, et al. Defendants.

          RICHARD A. SCHONFELD, ESQ. Nevada Bar No. 6815 CHESNOFF & SCHONFELD JOHN BURTON, Pro Hac Vice California Bar No. 86029 THE LAW OFFICES OF JOHN BURTON Attorneys for Plaintiff's, Stacey M. Rivhards.

          HEATHER B. ZANA Deputy Attorney General Attorneys for Defendants.

          STIPULATION AND REQUEST TO EXTEND DISCOVERY AND OTHER DEADLINES (3rd REQUEST)

          PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE.

         IT IS HEREBY STIPULATED by and between Plaintiff, STACEY M. RICHARDS, by his counsel Richard A. Schonfeld, Esq., of the law offices of Chesnoff & Schonfeld, and John Burton, Esq., of the law offices of John Burton, and Heather B. Zana, Deputy Attorney General, counsel for Defendants, Greg Cox, et al, pursuant to FRCP 26(f) and Local Rule 26-1(e), that the discovery deadline dates and trial of this matter, shall be extended by at least ninety days with the close of Discovery being May 9, 2018, subject to this Court's approval:

         The Parties seek to modify the Scheduling Order to extend the discovery cut-off date and the motion cut-off date. This is necessary in order to effectively proceed with discovery herein.

         1. Plaintiff s Complaint was filed on July 28, 2016;

         2. Defendants Eric Boardman, Michael Byrne and William Gittere's Answer was filed on September 29, 2016;

         3. Defendant Michael Fletcher's Answer to Complaint was filed on October 14, 2016;

         4. Defendants Renee Baker and Greg Cox's Answer to Complaint was filed on November 1, 2016;

         5. Counsel conducted the required case conference on October 5, 2016. Plaintiff was represented by Richard A. Schonfeld of Chesnoff and Schonfeld and John Burton of the law offices of John Burton. Defendants were represented by Clark B. Leslie, Chief Attorney General;

         6. On November 9, 2016, this Honorable Court entered an Order setting discovery deadlines;

         7. On February 8, 2017, Plaintiff Initial Disclosures were electronically served on Defendant;

         8. On February 21, 2017, Plaintiff received Defendant's Initial Disclosures;

         9. Plaintiff served Requests for Production of Documents, First Set of Interrogatories and Request for Admissions to Defendants and Mr. Leslie served Defendant's Requests for Production of Documents and First Set of ...


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