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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,
v.
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.

          ADAM GANZ, ESQ. MARJORIE HAUF, ESQ. CARA XIDIS, ESQ. Attorneys for the Plaintiffs

          Crystal Herrera, Esq.Clark County School District Office of General Counsel Attorneys for Defendants

          STIPULATION AND ORDER TO EXTENDDISCOVERY DEADLINES (FIRST REQUEST)

         Plaintiffs 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.

         I. 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 FRCP 26(a)(1);
B. Defendants have propounded written discovery requests upon Plaintiffs;
C. Plaintiffs have responded to written discovery requests.

         II. 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 ...

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