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Eliason v. Clark County

United States District Court, D. Nevada

May 22, 2018

ROBERT ELIASON, an individual and in his official capacity as Constable of North Las Vegas Township, Plaintiff,
v.
CLARK COUNTY, a political subdivision of the State of Nevada; STATE OF NEVADA ex rel NEVADA COMMISSION ON PEACE OFFICER STANDARDS & TRAINING, a regulatory agency of the State of Nevada, Defendants.

          EVANS FEARS & SCHUTTERT LLP KELLY A. EVANS, ESQ. CHAD R. FEARS, ESQ. ASHCRAFT & BARR LLP JEFFREY F. BARR, ESQ. ATTORNEYS FOR PLAINTIFF ROBERT ELIASON

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI THOMAS D. DILLARD, JR., ESQ. ATTORNEYS FOR DEFENDANT CLARK COUNTY

          ADAM P. LAXALT, ATTORNEY GENERAL MICHAEL D. JENSEN, ESQ. ATTORNEYS FOR DEFENDANT STATE OF NEVADA EX REL. NEVADA COMMISSION ON PEACE OFFICERS STANDARDS AND TRAINING

          STIPULATION AND ORDER EXTENDING TIME TO COMPLETE DISCOVERY

         Pursuant to LR IA 6-1 and LR 26-4, Plaintiff ROBERT ELIASON, Defendant CLARK COUNTY and Defendant STATE OF NEVADA ex rel. NEVADA COMMISSION ON PEACE OFFICER STANDARDS & TRAINING (collectively, “the Parties”), for good cause shown, hereby stipulate and agree to extend discovery deadlines in this matter by 90 days. This is the Parties' first request.

         I. GOOD CAUSE SUPPORTS AN EXTENSION

         Rule 6(b)(1) of the Federal Rules of Civil Procedure and LR 26-4 permit the Court to extend discovery deadlines “for good cause.” To determine “good cause, ” the court “primarily considers the diligence of the party or parties seeking the extension.” Liguori v. Hansen, 2012 U.S. Dist. LEXIS 30076 at 20, 2:11-cv-00492 (D. Nev. March 6, 2012), citing Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992).

         1. This request is made well before 21-days before the expiration of the relevant discovery deadlines.

         2. As shown below, the Parties have diligently pursued discovery.

         3. As shown below, information disclosed pursuant to this diligent discovery necessitates the need to adjust deadlines in this case.

         4. No. party will be prejudiced by an extension of the deadlines in this case.

         II. DISCOVERY COMPLETED TO DATE

         To date, the Parties have engaged in the following discovery: .

• Initial Disclosures from Plaintiff and Defendant County--January 30, 2018.
• Initial Disclosures from Defendant NV POST--February ...

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