United States District Court, D. Nevada
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,
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
L. Wilson, Esq. JONES WILSON LLP., Attorney for Plaintiffs.
Felicia Galati, Esq., OLSON, CANNON, GORMLEY, ANGULO &
STOBERSKI Attorney for Defendants.
M. Ressler, Esq., LAW OFFICES OF RESSLER & TESH, Attorney
AMENDED STIPULATION AND ORDER TO EXTEND
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
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.
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
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
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 ...