Bryant v Madison Management Services, LLC, et al

Filing 59

ORDER Granting 55 Motion to Extend Time - Discovery due by 1/24/2022. Motions due by 2/18/2022. Proposed Joint Pretrial Order due by 3/20/2022. Signed by Magistrate Judge Elayna J. Youchah on 12/9/2021. (Copies have been distributed pursuant to the NEF - DRS)

Nicholas M. Porras, Esq.
Nevada Bar No.: 12849
Waldman & Porras, PLLC
201 West Liberty St. Suite 207
Reno, NV 89501
Telephone: [phone] | Fax: [phone]
[e-mail]
[e-mail]
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

LISA A. BRYANT,
PLAINTIFF,

Case No.: 2:20-cv-00594-JAD-EJY
EMERGENCY MOTION FOR
EXTENSION OF TIME TO EXTEND
DISCOVERY

vs.
MADISON MANAGEMENT SERVICES,
LLC, AND WALDMAN & PORRAS, PLLC,
DEFENDANTS.

COMES NOW, Defendants, Madison Management Services, LLC and Waldman &
Porras, PLLC (collectively hereinafter as “Defendant”), by and through their attorney of record,
Nicholas M. Porras, Esq, of the law firm of Waldman & Porras, PLLC, and Pursuant to Fed. R.
Civ. P. 26(f), and Local Rule 26-1, and hereby files this Motion for Extension of Time, and states
as follows:
1. On or about March 27, 2020, Plaintiff filed her Complaint in the instant action.
2. On or about February 1, 2021, this Court issued its Scheduling Order [Doc. No. 39].
3. On or about March 25, 2021, Plaintiff and Defendant entered into a Stipulation for
Extension of Time of the Scheduling Order [Doc. No. 43].

4. On or about July 15, 2021, Plaintiff and Defendant entered into a Second Stipulation
for Extension of Time of the Scheduling Order [Doc. No. 53].
5. Defendant is hereby respectfully requesting this Court enter an Order Extending the
Scheduling Order Deadlines by forty-five (45) days to allow Defendants time so that
they may comply with this Court’s Scheduling Order.
6. The parties have exchanged initial disclosures and completed most written discovery.
7. Defendants currently need to depose the Plaintiff and the notary witness. Additional
documents outstanding may be revealed at these depositions.
8. Good Cause exists such that Defendants need the depositions to proceed with their
case. Plaintiff’s counsel and the undersigned had a conversation on or about
10/13/21where he disclosed he had a considerable number of documents to send me.
There were also discussions that Defendants need to depose the Plaintiff and the
notary witness which necessitate the documents to be produced. Plaintiff sent the
documents some time after the conversation from a different no-reply type email
address which due to size or origination ended up in the undersigned’s spam folder.
The undersigned assumed that retrieving documents from Plaintiff’s client was taking
additional time as to why documents were not received and that the parties would Stip
to an extension as Defendants did per the Plaintiff’s previous request for an extension.
Upon request for a stip for an extension of time, Plaintiff’s counsel resent the
documents on 12/6/21.
9. The current deadlines are as follows:
 Discovery Cutoff: December 8, 2021
 Deadline to Amend Pleadings: September 9, 2021

 Deadline to Disclose Initial Expert Disclosures: October 11, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: November 10, 2021
 Dispositive Motion Deadline: January 4, 2022
 Joint Proposed Pretrial Order: February 3, 2022

10. Defendant would request the following proposed deadlines be put in place:
 Discovery Cutoff: January 24, 2022
 Deadline to Amend Pleadings: October 24, 2021
 Deadline to Disclose Initial Expert Disclosures: November 25, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: December 27, 2021
 Dispositive Motion Deadline: February 18, 2022
 Joint Proposed Pretrial Order: March 20, 2022

11. No prejudice will occur to this Court or the Parties if granted and good cause
supports this request to extend discovery. Defendants will be greatly prejudiced if
they are unable to proceed with the depositions.
12. The undersigned has contacted Plaintiff’s counsel by phone and email and sent a
Proposed Stip but has not received a response, which necessitated the need for the
filing of this motion.

WHEREFORE, PREMISES CONSIDERED, Defendant respectfully requests this
Court enter an Order Continuing the Scheduling Order Deadlines for a date approximately
forty-five (45) days out, together with such further relief and this Honorable Court deems
Defendant is entitled.

DEFENDANTS, MADISON
MANAGEMENT SERVICES, LLC AND
WALDMAN & PORRAS, PLLC’S
EMERGENCY MOTION FOR
EXTENSION OF TIME
Dated December 7, 2021
/s/ Nicholas M. Porras
Nicholas M. Porras, Esq.
Nevada Bar No.: 12849

ORDER
IT IS SO ORDERED.
Dated this 9th day of December, 2021.
_________________________________________
UNITED STATES MAGISTRATE JUDGE