Filed: Feb. 15, 2018
Latest Update: Feb. 15, 2018
Summary: 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 RICHARD WHITLEY; KELLY WOOLRIDGE; DONALD BURNETTE; CLARK COUTNY; TIMOTHY BURCH; JAMES HARDEE; and HOPELINK OF SOUTHERN NEVADA, by and through their attorneys of record, pursuant to LR IA 6-1 and LR 26-4 an
Summary: 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 RICHARD WHITLEY; KELLY WOOLRIDGE; DONALD BURNETTE; CLARK COUTNY; TIMOTHY BURCH; 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..
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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 RICHARD WHITLEY; KELLY WOOLRIDGE; DONALD BURNETTE; CLARK COUTNY; TIMOTHY BURCH; 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 first request for an extension of the discovery deadlines.
(a) A STATEMENT OF DISCOVERY COMPLETED TO DATE:
Plaintiffs, Richard Whitley and Kelly Wooldridge ("State 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. Clark County has propounded written discovery requests to Plaintiffs, including interrogatories, requests for production and requests for admission. Plaintiffs' responses are due on February 27, 2018. Plaintiffs have propounded written discovery requests to Defendants Hopelink, Frank Hardee and Clark County, including interrogatories and requests for production. James Hardee's and Hopelink's responses were due on February 9, 2018 and Clark County's responses were due on February 12, 2018.
(b) A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:
(1) Defendants anticipate taking the deposition of Bernadine Morimoto;
(2) Plaintiffs anticipate taking the depositions of Defendants James Hardee; Karen Kyger; the 30(b)(6) witness for Hopelink of Southern Nevada; 30(b)(6) witness for Clark County; Timothy Burch; Donald Burnette; Richard Whitley; and Kelly Woolridge;
(3) Subpoenas to Las Vegas Metropolitan Police Department;
(4) Disclosure of expert witnesses;
(5) Depositions of the parties' expert witnesses;
(6) Additional document production
(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' first request for an extension of the discovery deadlines. The parties are currently awaiting orders from the Court regarding Defendants' 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. Clark County will make its substantive document disclosures on February 22, 2018. This request is being filed more than 21 days before the expiration of the discovery deadline. The parties are seeking a 120-day continuance of below referenced dates.
(d) A PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY:
Description: Current Deadline: Proposed Deadline:
Expert disclosure deadline March 9, 2018 July 6, 2018
Rebuttal expert disclosure April 9, 2018 August 6, 2018
Discovery Deadline May 8, 2018 September 5, 2018
Dispositive Motion Deadline June 7, 2018 October 5, 2018
Pre-Trial Order Deadlines July 6, 2018 November 2, 2018
Amend Pleadings and Add Parties February 7, 2018 June 7, 2018
Interim Status Report March 9, 2018 July 6, 2018
IT IS SO ORDERED.
