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Thomas v. Dade
United States District Court, D. Nevada
November 19, 2019
DESHUN THOMAS, individually, and as Natural Parent and Guardian for L.J., and KRISTIN WOODS as Co-Guardian Ad Litem for L.J., Plaintiffs,
BEVERLY DADE, individually, and in her official capacity; RICHARD FULLER, individually, and in his official capacity; PATRICIA SCHULTZ, individually, and in her official capacity; PAT SKORKOWSKY, individually, and in his official capacity; CLARK COUNTY SCHOOL DISTRICT, a Political Subdivision of the State of Nevada, DOE TEACHER'S AIDE, in his/her official capacity; DOES I through X, inclusive; and ROES I through X, inclusive, Defendants.
GANZ, ESQ. MARJORIE HAUF, ESQ. CARA XIDIS, ESQ. Attorneys for
Crystal Herrera, Esq.Clark County School District Office of
General Counsel Attorneys for Defendants
STIPULATION AND ORDER TO EXTENDDISCOVERY DEADLINES
Pursuant to Fed R. Civ. P. 6, Fed.R.Civ.P. 26, LR IA 6-1, LR
IA 6-2, LR 7-1, and LR 26-4, the parties, by and through
their respective counsel of record, stipulate and agree that
there is good cause to extend the discovery deadlines in the
operative discovery plan [ECF No. 35], as set forth below.
Pursuant to LR 26-4(a), the parties stipulate that the
following discovery has been completed:
A. The parties have served initial disclosures pursuant to
B. Defendants have propounded written discovery requests upon
C. Plaintiffs have responded to written discovery requests.
Pursuant to LR 26-4(b), the parties stipulate that they
need to complete the following discovery:
A. Depositions of the parties;
B. Depositions of percipient and lay witnesses;
C. Designation of initial experts and rebuttal experts;
D. Depositions of expert witnesses;
E. Production of additional documents;
F. Additional written discovery ...