United States District Court, D. Nevada
OFFICE OF MICHAEL P. BALABAN MICHAEL P. BALABAN, ESQ.
ATTORNEYS FOR PLAINTIFF
BRISBOIS BISGAARD & SMITH LLP ROBERT W. FREEMAN, ESQ.
DANIELLE C. MILLER, ESQ. ATTORNEYS FOR DEFENDANT CLARK COUNTY
STIPULATION AND ORDER TO EXTEND DISCOVERY
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:
Plaintiff filed her Complaint on December 22, 2017. (ECF No.
February 14, 2018, Defendant Clark County filed an Answer to
Plaintiff's Complaint. (ECF No. 9).
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).
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
compliance with Local Rule 26-4, the parties provide the
following information ...