Woodard v. Cox et al

Filing 109

ORDER Granting 108 Motion to Extend Time (Sixth Request). Discovery due by 11/14/2016. Motions due by 12/12/2016. Proposed Joint Pretrial Order due by 1/12/2017. Signed by Magistrate Judge Nancy J. Koppe on 10/13/2016. (Copies have been distributed pursuant to the NEF - NEV)

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ADAM PAUL LAXALT
Attorney General
JARED M. FROST (Bar No. 11132)
Senior Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E Washington Ave, Suite 3900
Las Vegas, Nevada 89101
[phone] (phone)
[phone] (fax)
Email: [e-mail]
Attorneys for Defendants
James Cox, Brian Williams, Romeo Aranas,
Francisco Sanchez, Frank Dreesen,
Benedicto Guitierrez, Fred Richardson,
and Cheryl Dressler

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Case No. 2:13-cv-01379-RFB-PAL

GUY R. WOODARD,

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Plaintiff,
DECLARATION OF COUNSEL

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vs.

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JAMES COX, et al.,
Defendants.

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I, JARED M. FROST, hereby declare, based on personal knowledge and/or

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information and belief, that the following assertions are true:
1.

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I am a Senior Deputy Attorney General employed by the Nevada Attorney

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General in the Litigation Division, and I make this declaration on behalf of Defendants’

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motion to extend discovery and remaining scheduling deadlines.
2.

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By this motion, I am requesting a thirty (30) day extension of the remaining

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discovery and scheduling deadlines. This is the sixth request to extend the discovery and

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scheduling deadlines filed in this matter.

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3.

On October 7, 2016, I spoke with Plaintiff’s counsel by phone. Plaintiff’s

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counsel indicated that Plaintiff was still interested in settlement and that he and

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Plaintiff were awaiting a statement to determine the amount of medical costs Plaintiff

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may be required to pay Nevada Medicaid pursuant to the settlement agreement. In

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addition, Plaintiff’s counsel agreed that a further extension of the remaining deadlines

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will likely be needed in this case. Later that day, I also spoke with counsel’s assistant who

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confirmed that Plaintiff had requested a final statement from Nevada Medicaid on

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August 28, 2016, and that Plaintiff was informed that the statement would be provided

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within thirty days of the request.

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4.

On October 12, 2016, Plaintiff’s counsel confirmed by phone that he did not

oppose Defendants’ motion for a sixth extension of the remaining scheduling deadlines.
Pursuant to 28 U.S.C. section 1746, Declarant certifies, under penalty of perjury,
that the foregoing is true and correct.
DATED this 12th day of October, 2016.
ADAM PAUL LAXALT
Attorney General
By:

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/s/ Jared M. Frost
JARED M. FROST (Bar No. 11132)
Senior Deputy Attorney General

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Attorneys for Defendants

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