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Grive v. Clark County

United States District Court, D. Nevada

July 5, 2018

SONIA GRIVE, Plaintiff,
v.
CLARK COUNTY, a political subdivision, and municipality, including its department, CLARK COUNTY ELECTION DEPARTMENT, Defendants.

          LAW OFFICE OF MICHAEL P. BALABAN MICHAEL P. BALABAN, ESQ. ATTORNEYS FOR PLAINTIFF

          LEWIS BRISBOIS BISGAARD & SMITH LLP ROBERT W. FREEMAN, ESQ. DANIELLE C. MILLER, ESQ. ATTORNEYS FOR DEFENDANT CLARK COUNTY

          STIPULATION AND ORDER TO EXTEND DISCOVERY

         Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of record, hereby stipulate and request that this Court extend discovery in the above-entitled matter by ninety (90) days, up to and including November 9, 2018. The parties also request that the dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days. In support of this Stipulation, the parties provide as follows:

         1. Plaintiff filed her Complaint on December 22, 2017. (ECF No. 1)

         2. On February 14, 2018, Defendant Clark County filed an Answer to Plaintiff's Complaint. (ECF No. 9).

         3. On March 5, 2018, the parties held their F.R.C.P. 26 conference and on March 8, 2108, the parties filed their initial Stipulated Discovery Plan and Scheduling Order in compliance with F.R.C.P. 26(f) and LR 26-1(e). (ECF No. 13).

         4. On March 9, 2018, U.S. Magistrate Judge Cam Ferenbach established the following discovery plan (ECF No. 27):

Last day of discovery: August 13, 2018
Last day to amend/add: May 5, 2018
Initial expert disclosure: June 14, 2018
Rebuttal expert disclosure: July 13, 2018
Dispositive motions filed: September 12, 2018
Joint pre-trial order: October 12, 2018

         5. In compliance with Local Rule 26-4, the parties provide the following information ...


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