United States District Court, D. Nevada
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
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.
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
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).
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.
SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE
COMPLETED (LR26-4 (b))
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
REASONS FOR REQUESTED EXTENSION (LR26-4 (c))
parties attended and participated in an ENE on July 27, 2017,
but there was no settlement.
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.
PROPOSED SCHEDULE FOR COMPLETING DISCOVERY (LR26-4
to LR 26-4, the parties propose to extend the current
deadlines and jointly ...