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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1 2 3 4 5 6 RYAN ALEXANDER Nevada Bar No. 10845 RYAN ALEXANDER, CHTD. 3017 West Charleston Blvd., Ste. 58 Las Vegas, NV 89102 Phone: (702) 868-3311 Fax: (702) 822-1133 Ryan@RyanAlexander.us Attorney for Plaintiff UNITED STATES DISTRICT COURT 7 8 9 10 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) 11 12 13 Related Case: Case No. 2:15-cv-01872-RFBNJK 14 15 Defendants. 16 17 KRISTIN TRUEMAN (“Trueman”), by and through her counsel of record, Ryan Alexander, 18 and Defendant CLARK COUNTY by and through its counsel Robert J. Gower, Esq., respectfully 19 move for the entry of the attached proposed Stipulation for a Limited Stay of Discovery until such 20 time that Defendant’s Motion to Dismiss may be heard and decided. 21 The Complaint in this case was filed on November 4, 2016. A subsequent Motion to Dismiss 22 was filed by Defendant CLARK COUNTY on December 21, 2016. There is also a pending Motion 23 to Dismiss in related case 2:15-cv-01872-RFB-NJK that could be dipositive of the case. The parties 24 agree that a stay of discovery proceedings until Defendant’s Motion to Dismiss would be beneficial 25 to the Parties and conserve efficient use of the Court’s resources while the Motion to Dismiss is 26 27 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. 28 1 1 2 3 4 5 6 7 8 9 10 11 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. 12 13 14 15 16 17 18 /s/Ryan Alexander __________________________________ RYAN ALEXANDER Nevada Bar No. 10845 3017 West Charleston Blvd., Ste. 58 Las Vegas, NV 89102 Phone: (702) 868-3311 Fax: (702) 822-1133 Ryan@RyanAlexander.us 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: 702-455-4761 Fax: 702-328-5178 Email: Robert.Gower@ClarkCountyDA.com Attorneys for Defendants LVMPD and Former Sheriff Doug Gillespie 19 20 21 22 IT IS SO ORDERED: The parties’ stipulation to stay all FRCP 26(f) duties, including submission of a proposed 23 Discovery Plan and Scheduling Order, until after an Order is entered on Defendant’s Motion to 24 Dismiss, is granted. The parties shall confer and submit their Discovery Plan and Scheduling Order 25 within twenty (20) days of the ruling on the Defendant’s Motion to Dismiss. 26 27 28 ______________________________________ UNITED STATES MAGISTRATE JUDGE 2/10/17 DATED: ___________________ 2 CERTIFICATE OF SERVICE 1 2 I hereby certify that I am an employee of Ryan Alexander Chtd., and on the 9th day of 3 February 2017, the foregoing STIPULATION AND ORDER TO STAY DISCOVERY was served 4 5 6 7 8 9 10 11 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: 702-328-5178 Email: ROBERT.GOWER@ClarkCountyDA.com Attorney for Defendants Clark COunty 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 /s/Ryan Alexander _________________________________ An Employee of Ryan Alexander, Chtd.

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