Blanton v. Louis DeJoy

Filing 24

ORDER Granting 23 Stipulation for Extension of Time. Discovery due by 6/10/2025. Motions due by 7/10/2025. Proposed Joint Pretrial Order due by 8/11/2025. Signed by Magistrate Judge Elayna J. Youchah on 1/28/2025. (Copies have been distributed pursuant to the NEF - AMMi)

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1 SUE FAHAMI Acting United States Attorney 2 District of Nevada 3 Nevada Bar No. 5634 VIRGINIA T. TOMOVA 4 Assistant United States Attorney Nevada Bar No. 12504 5 501 Las Vegas Blvd. So., Suite 1100 Las Vegas, Nevada 89101 6 (702) 388-6533 Virginia.Tomova@usdoj.gov 7 Attorneys for Federal Defendant 8 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 9 10 JOVAN P. BLANTON, Case No. 2:23-cv-02102-RFB-EJY Plaintiff, Stipulation and Order to Extend Discovery Deadlines (First Request) 11 12 v. 13 LOUIS DEJOY, Postmaster General, 14 15 Defendant. Pursuant to LR IA 6-1 and LR 26-3, the parties request a 90-day extension of certain 16 discovery deadlines as, and for the reasons, set forth below. There is a good cause for such 17 extension as the parties have conducted discovery diligently and in good faith. However, the 18 parties need additional time to complete discovery including taking depositions and 19 responding to discovery. Some of the witnesses are not available for a deposition until after 20 the close of discovery. The parties request the extension of the close of discovery, dispositive 21 motions and pretrial order deadlines. This is the first request for an extension of the 22 discovery schedule. 23 DISCOVERY COMPLETED 24 The parties served their respective initial disclosures. Federal Defendant served 25 discovery requests on Plaintiff, which Plaintiff is in the process of responding. 26 27 DISCOVERY REMAINING The parties need to conduct depositions of the plaintiff, his former supervisors with 28 the United States Postal Service and any other percipient witnesses. 1 WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED 2 The parties respectfully request the additional time to finish discovery in this 3 employment discrimination case by conducting depositions and responding to discovery. 4 The reason why the remaining discovery has not been completed is due to the parties and 5 witnesses’ schedules. Due to the scheduling issues, some witnesses are not available for a 6 deposition until after the close of discovery which currently is March 10, 2025. For these 7 reasons and in good cause, the parties request the 90-day extension of all remaining discovery 8 deadlines. 9 EXTENSION OF THE DISCOVERY PLAN AND SCHEDULING ORDER 10 The following table sets forth the current deadlines and the proposed extended 11 deadlines that are the subject of this stipulated request: 12 SCHEDULED EVENT 13 Rebuttal Expert Disclosures Discovery Cutoff Dispositive Motions Proposed Joint Pretrial Order 14 15 16 17 18 19 20 21 22 23 24 25 26 CURRENT DEADLINE February 10, 2025 March 10, 2025 April 9, 2025 May 9, 2025 PROPOSED DEADLINE February 10, 2025 June 10, 2025 July 10, 2025 August 11, 20251 /// /// /// /// /// /// /// /// /// /// 27 If dispositive motions were filed, the deadline for the Proposed Joint Pretrial Order would be deferred until 30 days after the Court rules on the dispositive motions. 1 28 2 1 2 3 This request for an extension of time is not sought for any improper purpose including delay. Respectfully submitted this 28th day of January 2025. 4 5 6 7 8 9 10 LAW OFFICE OF MICHAEL B. BALABAN SUE FAHAMI Acting United States Attorney /s/ Michael B. Balaban MICHAEL B. BALABAN Nevada Bar No. 9370 10726 Del Rudini Street Las Vegas, Nevada 89141 Attorneys for Plaintiff /s/ Virginia T. Tomova VIRGINIA T. TOMOVA Assistant United States Attorney IT IS SO ORDERED: 11 12 UNITED STATES MAGISTRATE JUDGE 13 14 DATED: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 January 28, 2025

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