United States District Court, D. Nevada
JOHNNY L. KENDRICK, JR., Plaintiff,
CLARK COUNTY, a political subdivision of the State of Nevada; JOHN MARTIN in his official and/or individual capacities; PATRICK SCHREIBER in his official and/or individual capacities; CAROLYN BANKS, in her official and/or individual capacities; and, SANDY JEANTETE, in her official and/or individual capacities, Defendants.
P. Kemp, Esq., Victoria L. Neal, Esq., Kemp & Kemp,
Attorneys for Plaintiff Johnny Kendrick Jr.
B. Wolfson, District Attorney, Scott R. Davis Deputy District
Attorney Attorneys for Defendant Clark County, John Martin,
Patrick Schreiber, and Sandy Jeantete.
STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND
GEORGE W. FOLEY, JR. UNITED STATES MAGISTRATE JUDGE.
to Local Rules IA 6-1 and 26-4, Plaintiff JOHNNY L. KENDRICK
(“Plaintiff”) by and through its counsel, Kemp
& Kemp, and Defendant CLARK COUNTY
(“Defendant”), by and through its counsel, Clark
County District Attorney, hereby stipulate to amend the
Discovery Plan and Scheduling Order (ECF No. 24) by extending
the outstanding discovery deadlines for a period of sixty
(60) days. This is the first request for an extension to the
discovery plan and scheduling order in this matter. The
requested extension is sought in good faith and not for
purposes of delay.
FOR REQUESTING EXTENSION
parties have worked diligently and cooperatively in resolving
discovery issues in this matter so as to avoid intervention
by the Court. This includes, but is not limited to, allowing
additional time to answer formal written discovery requests.
Currently, the parties are engaged in amicable discussions to
resolve issues surrounding the production of non-party
employee comparator files and finalizing a negotiated
protective order. Production of these comparator files is
critical to prosecute and/or defend this case and requires
the utmost care to protect any possible privacy concerns of
the non-party employee comparators. In addition, the parties
have engaged in further settlement discussions. If this
matter could be resolved, this would save the parties and the
Court valuable time and resources. Finally, Plaintiff's
counsel has two (2) trials set for the month of April (one in
Federal Court and one in State Court), and Defendant's
counsel has trial set for the month of May.
DISCOVERY COMPLETED TO Dated:
Initial disclosures to Defendant September 12, 2018
First supplemental disclosures to Defendant November 16, 2018
First set of written discovery to Defendant January 18, 2019
Second supplemental disclosures to Defendant February ...