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Anderson v. Dzurenda

United States District Court, D. Nevada

December 3, 2019

JOSEPH M. ANDERSON, Plaintiff,
v.
JAMES DZURENDA, et al., Defendants.

          AARON D. FORD Attorney General DOUGLAS R. RANDS, Bar No. 3572 Senior Deputy Attorney General State of Nevada Public Safety Division Attorneys for Defendants Kim Adamson, Romeo Aranas, Veronica Austin, Renee Baker, Susan Baros, Fransisco Bautista, Dwayne Baze, Quentin Byrne, David Carpenter, Tara Carpenter, Ian Carr, Anthony Carrasco, Nichole Cordova, James "Greg" Cox, Scott Davis, Russell Donnelly, James Dzurenda, Arwen Feather, Gilberto Florio-Ramirez, Sheryl Foster, Tom Garrett, Cor alee Gorsline, Katherine Hegge, Desiree Hultenschmidt, William Kablitz, Alan Lima, Dominick Martucci, E.K. McDaniel, Valaree Olivas, William Sandie, Richard Snyder, James Stogner, Roger Terrance, Kim Thomas, Joy Walsh, Harold Wickham and Catherine Yup.

          MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO PLAINTIFFS MOTIONS TO COMPEL DISCOVERY, (ECF NOS. 123, 124 AND 125)

         Defendants, Kim Adamson, Romeo Aranas, Veronica Austin, Renee Baker, Susan Baros, Francisco Bautista, Dwayne Baze, Quentin Byrne, David Carpenter, Tara Carpenter, Ian Carr, Anthony Carrasco, Jeffrey Chandler, Nichole Cordova, James "Greg" Cox, Scott Davis, Russell Donnelly, James Dzurenda, Arwen Feather, Gilberto Florio-Ramirez, Sheryl Foster, Tim Garrett, Coralee Gorsline, Katherine Hegge, Desiree Hultenschmidt, William Kablitz, Alan Lima, Dominick Martucci, E. K. McDaniel, Valaree Olivas, William Sandie, Richard Snyder, James Stogner, Roger Terance, Kim Thomas, Joy Walsh, Harold Wickham and Catherine Yup, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, Defendants David Carpenter, Pamela Feil, and Jason O'Dea, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, hereby submit their Motion for Extension of Time to File Responses to Plaintiffs Motions to Compel Discovery, (ECF Nos. 123, 124 and 125) (First Request). This Motion is based on Federal Rule of Civil Procedure 6(b)(1)(A), the following Memorandum of Points and Authorities, and all papers and pleadings on file in this action.

         MEMORANDUM OF POINTS AND AUTHORITIES

         I. ARGUMENT

         Defendants respectfully request a forty-five (45) day extension of time from the current deadline, (January 2, 2019) to respond to Plaintiffs Motions to Compel Discovery in this case. Defense counsel submits that the Plaintiffs Motions to Compel Discovery are extensive and fact specific. Plaintiff has moved for an order to compel additional and amended responses to multiple answers to interrogatories (ECF No. 123), requests for production of documents, (ECF No. 124) and requests for admissions. (ECF No. 125). The time to respond to these motions will be extensive.

         In this matter, the Defendants have responded to over 12 sets of interrogatories, 9 sets of requests for production of documents, and 11 sets of requests for admissions. Plaintiffs motions do not comply, strictly, with LR 26-7(b), in that the full text of the discovery originally sought is not set forth. Therefore, the responses will be more time consuming. Additionally, Counsel with the holidays are coming up, which is further stretching the resources of this office.

         Federal Rule of Civil Procedure 6(b)(1) governs extensions of time and provides as follows:

When an act may or must be done within a specified time, the court may, for good cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires; or (B) on motion made after the time has expired if the party failed to act because of excusable neglect.

         Defendants' request is timely and will not hinder or prejudice Plaintiffs case, but will allow for a thorough opportunity to respond to the discovery requests. The requested forty-five (45) day extension of time should permit the defendants time to adequately research draft, and submit responses to the motions to compel discovery in this case. Defendants assert that the requisite good cause is present to warrant the requested extension of time. Therefore, the Defendants request additional time, up until Thursday, January 16, 2020, to respond to the Motions.

         Plaintiff, in his motions also suggested a hearing relating to this issue. In light of the magnitude of discovery in this case, the ...


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