STIPULATION AND REOUEST TO EXTEND DISCOVERY AND OTHER DEADLINES (3RD REQUEST)

PEGGY A. LEEN, Magistrate Judge.

IT IS HEREBY STIPULATED by and between Plaintiff, STACEY M. RICHARDS, by his counsel Richard A. Schonfeld, Esq., of the law offices of Chesnoff & Schonfeld, and John Burton, Esq., of the law offices of John Burton, and Heather B. Zana, Deputy Attorney General, counsel for Defendants, Greg Cox, et al, pursuant to FRCP 26(f) and Local Rule 26-1(e), that the discovery deadline dates and trial of this matter, shall be extended by at least ninety days with the close of Discovery being May 9, 2018, subject to this Court's approval:

The Parties seek to modify the Scheduling Order to extend the discovery cut-off date and the motion cut-off date. This is necessary in order to effectively proceed with discovery herein.

1. Plaintiff's Complaint was filed on July 28, 2016;

2. Defendants Eric Boardman, Michael Byrne and William Gittere's Answer was filed on September 29, 2016;

3. Defendant Michael Fletcher's Answer to Complaint was filed on October 14, 2016;

4. Defendants Renee Baker and Greg Cox's Answer to Complaint was filed on November 1, 2016;

5. Counsel conducted the required case conference on October 5, 2016. Plaintiff was represented by Richard A. Schonfeld of Chesnoff and Schonfeld and John Burton of the law offices of John Burton. Defendants were represented by Clark B. Leslie, Chief Attorney General;

6. On November 9, 2016, this Honorable Court entered an Order setting discovery deadlines;

7. On February 8, 2017, Plaintiff Initial Disclosures were electronically served on Defendant;

8. On February 21, 2017, Plaintiff received Defendant's Initial Disclosures;

9. Plaintiff served Requests for Production of Documents, First Set of Interrogatories and Request for Admissions to Defendants and Mr. Leslie served Defendant's Requests for Production of Documents and First Set of Interrogatories and Request for Admissions directed to Plaintiff.

10. The parties had been gathering Plaintiff's medical records which include treatment with multiple providers in both Nevada and California, and therefore it has taken considerable time to compile the records;

11. The parties have been engaged in dialogue with an eye toward resolving this case. As a result, the parties had a joint call with one of the Plaintiff's surgeons that treated the Plaintiff after the incident in question. The purpose of the call was for the parties to gain insight as to the potential testimony of said witness without the need for a deposition at this time. The parties will continue their dialogue and anticipate attending a mediation;

12. The following depositions took place on October 23, 2017, in Los Angeles, California:

13. The following is a list of the current discovery deadlines and the parties' proposed extended deadlines.

14. The extension of the discovery deadline will necessitate a new trial date.

15. This is the third request for extension of time in this matter.

WHEREFORE, the parties respectfully request that this Court extend the discovery period by one hundred twenty [120] days from the close of current discovery deadlines. Similarly, the parties request that the expert and rebuttal expert deadlines, the dispositive motion and pretrial order deadlines be extended pursuant to the above-referenced schedule.

ORDER

The Court has reviewed the Stipulation of counsel and finds Good Cause to grant said Stipulation. Accordingly, IT IS ORDERED adopting the above Stipulation and Request to Extend Discovery and other Deadlines.

IT IS SO ORDERED.