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Wolf v. Clark County

United States District Court, D. Nevada

May 23, 2018

BRUCE WOLF, as Litigation Guardian Ad Litem for C.A.R., D.O.B. 1/19/2002, C.J.R., D.O.B. 1/17/2005 and G.Y.R., D.O.B 10/7/2006, Plaintiffs,
v.
CLARK COUNTY, SHAY RIGGS-HORN, ASHLEY DURROUGH, TROY ARMSTRONG AND JOHN AND JANE DOES I-10, Defendants.

          FELICIA GALATI, ESQ., ANGU.LO & STOBERSKI, Attorneys for Defendants CLARK COUNTY, SHAY RIGGS-HORN, ASHLEY DURROUGH and TROY ARMSTRONG.

          Justin L. Wilson, Esq. JONES WILSON LLP., Attorney for Plaintiffs.

          Felicia Galati, Esq., OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI Attorney for Defendants.

          Allen M. Ressler, Esq., LAW OFFICES OF RESSLER & TESH, Attorney for Plaintiffs.

          AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY

         Pursuant, to FRCP 6 and FRCP 26, the parties, by and through their respective counsel of record, hereby stipulate and agree to jointly move this Court for an. Order to:

1. Extend the date to disclose initial expert witnesses from 5/10/18 to 8/10/18
2. Extend the date to disclose rebuttal expert witnesses from 6/8/18 to 9/8/18
3. Extend the discovery cut-off date from 7/10/18 to 10/10/18
4. Extend the date to file dispositive motions from 8/8/18 to 11/8/18;
5. Extend the date to file the Joint Pre-Trial Order from 9/7/18 to 12/7/18. In the event dispositive motions are filed, the date set for filing the Joint Pre-Trial Order shall be suspended until thirty (30) days after the decision of the dispositive motions or further order of the court.

         1. DISCOVERY COMPLETED

         Defendant Clark County ("Defendant") made its initial witness and document disclosure pursuant to FRCP 26(a)(1) on 11/2/17, Plaintiffs made their initial witness and document disclosure pursuant to FRCP 26(a)(1) on 10/10/17, and three supplemental disclosures thereafter, the last one made on 4/2/18. Defendants made their first supplemental disclosure and eight supplemental disclosures thereafter, the last one made on 2/26/18, Defendants will make a ninth supplemental disclosure in the near future. Thousands of pages of documents have been produced by the parties in this case and more expect to be produced.

         Plaintiffs propounded written discovery to Defendant on 12/7/17, which Defendant responded to. Defendant propounded written discovery to Plaintiffs, to which Plaintiffs responded. Plaintiffs issued second interrogatories and requests for production and first requests for admission to Defendants, Those responses are due on 5/23/18. Defendant will issue some additional written discovery to Plaintiffs and/or are waiting for Plaintiffs to supplement their prior discovery responses based on those responses, II. GROUNDS FOR DISCOVERY EXTENSION

         On 4/10/18, Plaintiffs filed a Second Amended Complaint, this time naming Defendant Clark County Department of Family Services, which is an entity that cannot be sued. In addition, the Second Amended Complaint added three new Defendants - Shay Riggs-Horn, Ashley Durrough and Troy Armstrong. Mr. Armstrong is currently deployed and is not expected to return to his employment in or about June 20IS. Plaintiffs' recent discovery refers to and requires information from Mr. Armstrong, The discovery responses are due on 5/23/1.8, On 5/16/18, Plaintiffs filed a Third Amended Complaint against Clark County, etc, after the deadline to make initial expert disclosures in this case had passed on 5/10/18. Thus, the Third Amended Complaint was filed 6 days after the initial expert disclosure deadline had ...


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