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Jackson v. Nye County ex rel. New County Sherriff's Office

United States District Court, D. Nevada

March 9, 2018

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

          CALLISTER LAW GROUP MATTHEW Q. CALLISTER, ESQ. MITCHELL S. BISSON, ESQ. ATTORNEYS FOR PLAINTIFF

          ERICKSON, THORPE & SWAINTON, LTD REBECCA BRUCH, ESQ. ATTORNEYS FOR DEFENDANT NYE COUNTY

          STIPULATION AND ORDER TO EXTEND DEADLINES SET FORTH IN JOINT DISCOVERY PLAN AND SCHEDULING ORDER

         THE PARTIES HEREBY STIPULATE AND AGREE by and between Plaintiff KELLY JACKSON, by and through counsel of record Matthew Q. Callister, Esq. and Mitchell S. Bisson, Esq., of the law firm of Callister Law Group, and Defendant NYE COUNTY ex rel. NYE COUNTY SHERRIFF'S OFFICE and ANTONIO MEDINA, by and through counsel of record 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 November 22, 2017, Order to Extend Deadlines Set forth In Joint Discovery Plan (Doc No. 36) be amended and deadlines, as listed below, be extended ninety (90) days from the currently scheduled dates. This is the second 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 November 22, 2017, the Court approved a Stipulation to Extend Deadlines Set Forth in the Joint Discovery Plan and Scheduling Order (First Request).

         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 October 13, 2017, deposition to be vacated because of ongoing medical issues as well as trauma caused by her attendance at the Route 91 shooting in Las Vegas. On February 9, 2018, Defendant commenced Plaintiff's deposition, but was not able to complete the deposition because Plaintiff had not yet produced certain documents upon which she had relied in this case. On February 13, 2018, Defendant propounded Requests for Production of Documents on Plaintiff. On March 1, 2018, Defendant supplemented its FRCP 26 disclosures.

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

         Plaintiff needs to supplement its witness disclosures, respond to Requests for Production propounded by Defendants on February 13, 2018, and both parties need to take numerous depositions. Defendant reserves, and Plaintiff does not object to completion of the Plaintiff's deposition and take several other depositions. 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.

         Defendant commenced the deposition of Plaintiff on February 9, 2018. During said deposition discoverable yet undisclosed information was introduced by Plaintiff. Plaintiff is in the process of preparing supplemental disclosures and responding to Requests for Production. Defendant reserved the right to continue Plaintiff's deposition. Additionally, on April 11, 2018, counsel for Defendant will be undergoing a medical procedure that will require a two-week leave of absence. Therefore, this request is necessary to allow time for the parties 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 ...


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