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McNamara v. Hallinan

United States District Court, D. Nevada

March 18, 2019

THOMAS W. MCNAMARA, as the Court-Appointed Monitor for AMG Capital Management, LLC, et al, Plaintiff,
v.
CHARLES M. HALLINAN, et al, Defendants.

          SEMENZ 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)

         Defendants 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.[1] 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.

         Pursuant 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.

         A. Completed Discovery

         The following discovery has occurred:

         Plaintiff 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 Production;
7. Rule 30(b)(6) deposition notice on Defendant Hallinan ...

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