Trueman v. Clark County

Filing 19

ORDER Granting 18 Stipulation to Stay Discovery. See Order for details. Signed by Magistrate Judge Carl W. Hoffman on 2/10/17. (Copies have been distributed pursuant to the NEF - ADR)

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RYAN ALEXANDER
Nevada Bar No. 10845
RYAN ALEXANDER, CHTD.
3017 West Charleston Blvd., Ste. 58
Las Vegas, NV 89102
Phone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff
UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA
Case No.: 2:16-cv-02558-JCM-CWH
Hon. James C. Mahan

KRISTIN TRUEMAN, an Individual,
Plaintiff,
vs.

STIPULATION AND ORDER TO STAY
DISCOVERY

CLARK COUNTY, a political subdivision of
the State of Nevada; DOES I - X; and ROE
CORPORATIONS I-X, inclusive,

(FIRST REQUEST)

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Related Case: Case No. 2:15-cv-01872-RFBNJK

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Defendants.

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KRISTIN TRUEMAN (“Trueman”), by and through her counsel of record, Ryan Alexander,

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and Defendant CLARK COUNTY by and through its counsel Robert J. Gower, Esq., respectfully

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move for the entry of the attached proposed Stipulation for a Limited Stay of Discovery until such

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time that Defendant’s Motion to Dismiss may be heard and decided.

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The Complaint in this case was filed on November 4, 2016. A subsequent Motion to Dismiss

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was filed by Defendant CLARK COUNTY on December 21, 2016. There is also a pending Motion

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to Dismiss in related case 2:15-cv-01872-RFB-NJK that could be dipositive of the case. The parties

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agree that a stay of discovery proceedings until Defendant’s Motion to Dismiss would be beneficial

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to the Parties and conserve efficient use of the Court’s resources while the Motion to Dismiss is

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decided. The parties shall confer and submit their Discovery Plan and Scheduling Order within
twenty (20) days of the ruling on the Defendant’s Motion to Dismiss.

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KRISTIN TRUEMAN (“Trueman”), by and through her counsel of record, Ryan Alexander,
and Defendant CLARK COUNTY by and through its counsel Robert F. Gower, Esq,
HEREBY STIPULATE AND AGREE that the deadline for Plaintiff and Defendant to hold
their Rule 26(f) conference and file their proposed Discovery Plan and Scheduling Order, and any
other FRCP 26(f) duties, be stayed until this Court rules on Defendant’s Motion to Dismiss;
This stay is not brought in bad faith or for purposes of delay.
IT IS SO STIPULATED.
DATED this 9th day of February, 2017.
CLARK COUNTY DISTRICT ATTORNEY'S
OFFICE - CIVIL DIVISION

RYAN ALEXANDER, CHTD.

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/s/Ryan Alexander
__________________________________
RYAN ALEXANDER
Nevada Bar No. 10845
3017 West Charleston Blvd., Ste. 58
Las Vegas, NV 89102
Phone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

/s/Robert J. Gower, Esq.
Robert J. Gower, Esq.
500 S. Grand Central Pkwy 5th Flr
P.O.Box 552215
Las Vegas, NV 89155-2215
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants LVMPD and Former
Sheriff Doug Gillespie

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IT IS SO ORDERED:
The parties’ stipulation to stay all FRCP 26(f) duties, including submission of a proposed

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Discovery Plan and Scheduling Order, until after an Order is entered on Defendant’s Motion to

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Dismiss, is granted. The parties shall confer and submit their Discovery Plan and Scheduling Order

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within twenty (20) days of the ruling on the Defendant’s Motion to Dismiss.

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______________________________________
UNITED STATES MAGISTRATE JUDGE

2/10/17
DATED: ___________________

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CERTIFICATE OF SERVICE

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I hereby certify that I am an employee of Ryan Alexander Chtd., and on the 9th day of

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February 2017, the foregoing STIPULATION AND ORDER TO STAY DISCOVERY was served

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by CM/ECF system upon:
Robert J. Gower, Esq.
Clark County District Attorney's Office
Civil Division
500 S. Grand Central Pkwy 5th Flr
P.O.Box 552215
Las Vegas, NV 89155-2215
702-455-4761
Fax: [phone]
Email: [e-mail]
Attorney for Defendants Clark COunty

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/s/Ryan Alexander
_________________________________
An Employee of Ryan Alexander, Chtd.