United States District Court, D. Nevada
THOMAS W. MCNAMARA, as the Court-Appointed Monitor for AMG Capital Management, LLC, et al, Plaintiff,
CHARLES M. HALLINAN, et al, Defendants.
A KIRCHER RICKARD, Lawrence J. Semenza, III, Esq., Bar No.
7174 Christopher D. Kircher, Esq., Bar No. 11176 Jarrod L.
Rickard, Esq., Bar No. 10203 Adam J. Petitt (admitted Pro Hac
Vice) STRADLEY RONON STEVENS & YOUNG, LLP Attorneys for
Defendants Charles M. Hallinan and Hallinan Capital Corp.
UNOPPOSED MOTION TO AMEND THE DISCOVERY PLAN AND
SCHEDULING ORDER (FOURTH REQUEST)
Charles M. Hallinan ("Hallinan") and Hallinan
Capital Corp. (collectively, referred to as
"Defendants") hereby request, and Plaintiff does
not oppose, an extension to the dates and deadlines set forth
in the discovery plan and scheduling order (ECF No. 27, as
amended at ECF Nos. 39, 53, and 69). The earliest deadline
set by the current Scheduling Order is the fact discovery
cut-off of April 5, 2019. Accordingly, this Motion is timely
under LR 26-4. The parties have met and conferred
to discuss the extension and Plaintiff does not oppose
Defendants' request, but reports that he is otherwise
prepared to complete discovery within the current deadlines.
to Fed.R.Civ.P. 16(b)(4), LR IA 6-1, LR IA 6-2, and LR 26-4,
Defendants submit that good cause exists to approve this
extension. As detailed below, Defendants are requesting, and
Plaintiff does not oppose, additional time to reschedule and
complete the depositions of witnesses including
Hallinan's daughters, Linda and Carolyn Hallinan.
Defendants are also coordinating a deposition date for the
Plaintiff and at least one additional percipient witness.
following discovery has occurred:
has served Defendants with the following items:
1. Initial Disclosures Pursuant to Fed.R.Civ.P. 26(a)(1);
2. First Set of Interrogatories;
3. First Set of Requests for Production of Documents;
4. First Set of Requests for Admissions;
5. Responses to Defendants' First Set of Interrogatories;
6. Responses to Defendants' First Set of Requests for
7. Rule 30(b)(6) deposition notice on Defendant Hallinan