Lezama v. Clark County

Filing 19

ORDER granting 18 Stipulation re Discovery Deadlines. Discovery due by 3/21/2018. Motions due by 4/23/2018. Proposed Joint Pretrial Order due by 5/23/2018. Signed by Magistrate Judge Cam Ferenbach on 11/16/2017. (Copies have been distributed pursuant to the NEF - MMM)

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Michael P. Balaban State Bar No. 9370
LAW OFFICES OF MICHAEL P. BALABAN
10726 Del Rudini Street
Las Vegas, NV 89141
[phone]
Fax: [phone]
E-Mail: [e-mail]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ROLANDO LEZAMA,

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Plaintiff,
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vs.
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CLARK COUNTY, a political subdivision, and )
municipality including its department, CLARK )
COUNTY, DEPARTMENT OF AVIATION, )
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Defendant.
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CASE NO. 2:17-cv-00086-JAD-VCF
STIPULATION AND REQUEST TO
EXTEND DISCOVERY AND OTHER
DEADLINES
(First Request)

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COME NOW, Plaintiff, named above, by and through his counsel of record, MICHAEL P.

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BALABAN, ESQ., and Defendant, named above, by and through their counsel of record,
WHITNEY J. SELERT, ESQ., pursuant to Local Rule 26-4, herein stipulate, agree and make joint
application to extend the discovery cut-off and related dates for a period of ninety (90) days up to
and including March 21, 2018. The present discovery cut-off date is December 21, 2017 and no
calendar call date or trial date has been set.

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This request is being made timely in accordance with LR 26-4 and the prior scheduling

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order which provides that requests for further discovery extensions must be made no later than

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twenty-one (21) days before the existing discovery cut-off date, or here by November 30, 2017.

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This is the first request for an extension.

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This stipulation is made and based upon the following factors.

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Although counsels for both parties have been working diligently to complete the discovery

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in this case, they still have to take depositions and the current discovery cut-off is only a little over
a month away. In addition there is a meet and confer scheduled for November 20, 2017 which
could result in a motion to compel further discovery responses if a resolution to the discovery
dispute is not agreed to.

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To date the parties have both made their initial disclosures to the other side and both
Plaintiff and Defendant have propounded interrogatories and requests for production of documents
on the other side which have been responded to. Defendant has also propounded requests for
admissions on Plaintiff which have also been responded to. In addition Defendant has designated
an expert witness.

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Finally Defendant has currently noticed Plaintiff’s deposition for November 29, 2017 and

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Plaintiff has requested dates to depose Defendant employees Sandy Jeantete, Christine Santiago,

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James Chrisley, Lette Bonilla and Terrence McCarthy.

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As set forth above, the attorneys for the parties have diligently worked to complete

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discovery as expediently as possible and will continue to try to complete the remaining discovery

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in as expedient a manner as possible.

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Given the above, the parties request that the discovery period be extended as follows:

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Activity

Former Date

Requested Date

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Discovery Cut-Off Date

12/21/17

03/21/18

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Dispositive Motions

01/22/18

04/23/18

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02/21/18

05/23/181

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Pretrial Order

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In accordance with LR 26-4 the parties understand that any further requests for discovery

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extensions must be made no later than twenty-one days before the new proposed discovery cut-off

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date, ie. March 21, 2018, or no later than twenty-one days before any other deadline sought to be

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extended.

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LAW OFFICES OF MICHAEL P.
BALABAN
/s/ Michael P. Balaban
Michael P. Balaban, Esq.
10726 Del Rudini St.
Las Vegas, NV 89141
Attorney for Plaintiff

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/s/ Whitney J. Selert
Whitney J. Selert, Esq.
300 S. Fourth Street, Suite 1500
Las Vegas, NV 89101
Attorney for Defendant

Dated: November 16, 2017

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FISHER & PHILLIPS, LLP

Dated: November 16, 2017

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IT IS SO ORDERED:

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________________________________
UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
Dated: November 16 , 2017

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Or 30 days after the decision on the last dispositive motion.

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