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Jackson v. Nye County ex rel. Nye County Sherriff's Office

United States District Court, D. Nevada

July 31, 2018

KELLY JACKSON, an individual, Plaintiff,
v.
NYE COUNTY ex rel. NYE COUNTY SHERRIFF'S OFFICE; ANTONIO M. MEDINA Defendants.

          MATTHEW Q. CALLISTER, ESQ. Nevada Bar No. 1396 MITCHELL S. BISSON, ESQ. Nevada Bar No. 011920 CALLISTER LAW GROUP Attorneys for Plaintiff

          ERICKSON, THORPE & SWAINTON, LTD REBECCA BRUCH, ESQ. Nevada Bar No. 007289 Attorneys for Defendant Nye County

          STIPULATION AND ORDER TO EXTEND DEADLINES SET FORTH IN JOINT DISCOVERY PLAN AND SCHEDULING ORDER (FOURTH REQUEST)

         THE PARTIES HEREBY STIPULATE AND AGREE by and between Plaintiff KELLY JACKSON, by and through counsel of record Matthew Q. Callister, Esq. and Mitchell S. Bisson, Esq., of the law firm of Callister Law Group, and Defendant NYE COUNTY ex rel. NYE COUNTY SHERRIFF'S OFFICE, by and through counsel of record Rebecca Bruch, Esq., of the law firm of Erickson, Thorpe & Swainston, LTD., that, in accordance with LR 7-1 and 26-4 of the Local Rules of Practice for the United States District Court, District of Nevada, the Court's May 21, 2018 Order to Extend Deadlines Set forth in the Order to Extend Discovery Deadlines (Third Request) (Doc No. 40) be amended and deadlines, as listed below, be extended ninety (90) days from the currently scheduled dates. This is the fourth request to extend the deadlines by the parties.

         This request includes extensions of the deadline to complete discovery under Rule 26(a)(2), dispositive motions, the interim status report, and Joint Pretrial Order. The present and proposed new dates for these deadlines are set forth in Section D below. The extension is necessary to accommodate the completion of necessary depositions.

         A. STATEMENT SPECIFYING DISCOVERY COMPLETED (LR 26-4(a))

         The Rule 26(f) conference was held on April 19, 2017. Following the Rule 26(f) conference, the proposed Joint Discovery Plan and Scheduling Order was filed on May 2, 2017. The Court approved the proposed Discovery Plan and Scheduling Order on May 10, 2017. Defendant exchanged initial disclosures on July 18, 2017. Plaintiff exchanged initial disclosures on November 9, 2017. On November 22, 2017, the Court approved a Stipulation to Extend Deadlines Set Forth in the Joint Discovery Plan and Scheduling Order (First Request).

         On June 22, 2017, Defendant propounded Interrogatories upon Plaintiff, which Plaintiff responded to on July 31, 2017, Defendant propounded Notice of Deposition upon Plaintiff which was set for October 13, 2017. Plaintiff requested the October 13, 2017, deposition to be vacated because of ongoing medical issues as well as trauma caused by her attendance at the Route 91 shooting in Las Vegas. On February 9, 2018, Defendant commenced Plaintiff's deposition, but was not able to complete the deposition because Plaintiff had not yet produced certain documents upon which she had relied in this case. On February 13, 2018, Defendant propounded Requests for Production of Documents on Plaintiff. On March 1, 2018, Defendant supplemented its FRCP 26 disclosures. On March 9, 2018 the Court approved a Stipulation to Extend Deadlines Set Forth in the Joint Discovery Plan and Scheduling Order (Second Request). Defendant propounded supplemental Interrogatories on Plaintiff on May 7, 2018. On May 21, 2018, the Court approved a Stipulation to Extend Deadlines Set Forth in the Joint Discovery Plan and Scheduling Order (Third Request).

         On April 4, 2018, Plaintiff propounded Interrogatories and Requests for Production on Defendant, which Defendant responded to the Requests for Production on June 4, 2018 and the Interrogatories on June 12, 2018.

         On July 17, 2018, Plaintiff commenced the deposition of the Person Most Knowledgeable for Defendant. Defendant propounded Notice of Deposition of Plaintiff continuing Plaintiff's deposition, which is set for July 20, 2018.

         B. SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED (LR26-4 (b))

         Plaintiff needs to supplement its witness disclosures. Defendant needs to supplement its response to Requests for Production and Interrogatories propounded by Plaintiffs on April 4, 2018. Due to time constraints, the depositions of Plaintiff and Defendant's 30(b)(6) witness were not completed and are set to recommence on July 20, 2018. In light of the testimony given by Defendant's FRCP 30(b)(6) witness during her deposition on July 17, 2018, Plaintiff needs to depose six additional witnesses whose testimony is necessary to the defense of Plaintiff's claims. Three of the depositions include former and current governmental officials who have been identified as persons more knowledgeable on several FRCP 30(b)(6) topics discussed in the July 17, 2018 deposition.

         C. REASONS FOR REQUESTED EXTENSION (LR26-4 (c))

         The parties attended and participated in an ENE on July 27, 2017, but there was no settlement.

         Defendant commenced the deposition of Plaintiff on February 9, 2018. During said deposition discoverable yet undisclosed information was introduced by Plaintiff. Plaintiff is in the process of preparing supplemental disclosures. Plaintiff's continued deposition is currently set for July 20, 2018. Plaintiff commenced the deposition of the PMK for Defendant on July 17, 2018, which was unable to conclude. Plaintiff needs additional time for a continued deposition of the PMK for Defendant, three individuals identified as 30(b)(6) witnesses and three percipient witnesses. Calendaring conflicts within the time allotted for close of ...


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