STIPULATION TO MODIFY SCHEDULING ORDER DEADLINES (2nd REQUEST)

GEORGE FOLEY, JR., Magistrate Judge.

This Stipulation to modify the scheduling order is entered into by and between Plaintiff BERNADINE MORIMOTO, as Personal Representative of the Estate of Abygaile B. and legal guardian and maternal grandmother of Ember B. and Karriah M.; and Defendants DONALD BURNETTE; TIMOTHY BURCH; CLARK COUNTY; JAMES HARDEE; and HOPELINK OF SOUTHERN NEVADA, by and through their attorneys of record, pursuant to LR IA 6-1 and LR 26-4 and based upon the following. This is the second request for an extension of the discovery deadlines.

(a) A STATEMENT OF DISCOVERY COMPLETED TO DATE:

Plaintiffs and Defendants Clark County, James Hardee, and Hopelink have exchanged initial disclosures of documents and the names of individuals with knowledge of the facts pertaining to Plaintiffs' claims against Defendants and have supplemented those disclosures. The parties have propounded and responded to written discovery. The remaining parties have propounded and responded to written discovery. Plaintiffs have subpoenaed the records from Henderson Police Department and Las Vegas Metropolitan Police Department and are awaiting receipt of those documents for disclosure. Plaintiffs and Defendants are in the process of coordinating depositions.

(b) A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:

(c) THE REASON WHY DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY PLAN

The parties aver, pursuant to Local Rule 6-1, that good cause exists for the requested extension. The parties agree that, pending this Court's approval, extension of the discovery deadlines is appropriate. This is the parties' second request for an extension of the discovery deadlines. Defendants Hopelink of Southern of Nevada and James Hardee filed a motion for leave to add new parties and discovery was halted while the parties awaited this Court's decision on this Motion, which was denied without prejudice and re-filed on June 7, 2018. Additionally, the parties are currently awaiting an order from the Court regarding Defendants Clark County, Donald Burnette and Timothy Burch's Motions to Dismiss. The parties also wish to further investigate this case but given the ongoing criminal investigations and prosecutions of Justin Bennett and Sherry Bennett, access to this information is limited. This request is being filed more than 21 days before the expiration of the discovery deadline. The parties are seeking a 90-day continuance of below referenced dates.

(d) A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:

IT IS SO ORDERED.