Filed: Oct. 02, 2019
Latest Update: Oct. 02, 2019
Summary: STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF PLAINTIFF'S MOTION TO REMAND (First Request) CAM FERENBACH , Magistrate Judge . Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Defendant Aida Maxsam, ("Defendants") and Plaintiff Clark County ("Plaintiff") 1 , by and through their respective undersigned counsel, hereby stipulate and agree, and respectfully request that the Court stay the filing of a Discovery Plan and Scheduling Order required by Fed. R. Civ. P. 26(f) an
Summary: STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF PLAINTIFF'S MOTION TO REMAND (First Request) CAM FERENBACH , Magistrate Judge . Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Defendant Aida Maxsam, ("Defendants") and Plaintiff Clark County ("Plaintiff") 1 , by and through their respective undersigned counsel, hereby stipulate and agree, and respectfully request that the Court stay the filing of a Discovery Plan and Scheduling Order required by Fed. R. Civ. P. 26(f) and..
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STIPULATION AND ORDER TO STAY DISCOVERY PENDING RESOLUTION OF PLAINTIFF'S MOTION TO REMAND
(First Request)
CAM FERENBACH, Magistrate Judge.
Pursuant to LR IA 6-1 and 6-2, and pursuant to LR 7-1, Defendant Aida Maxsam, ("Defendants") and Plaintiff Clark County ("Plaintiff")1, by and through their respective undersigned counsel, hereby stipulate and agree, and respectfully request that the Court stay the filing of a Discovery Plan and Scheduling Order required by Fed. R. Civ. P. 26(f) and LR 26-l(d), and the conducting of all discovery in this action, pending this Court's resolution of Plaintiff's Motion to Remand Pursuant to Rules 28 U.S.C. § 1447(c) (the "Motion to Remand") (Dkt. No. 7). This is the Parties' first request to stay the filing of a Discovery Plan and Scheduling Order required by Fed. R. Civ. P. 26(f) and LR 26-l(d), and the conducting of all discovery, in this action.
On September 27, 2018, counsel for Defendant and Plaintiffs conducted a discovery teleconference pursuant to Fed. R. Civ. P. 26(f) and LR 26-l(d). During this conference, counsel respectfully agreed that a stay of all further discovery obligations under Fed. R. Civ. P. 26(f) and LR 26-l(d) is warranted pending the outcome of the Motion to Remand, and that said stay will preserve valuable judicial resources, party resources, and time pending resolution thereof.
If the Court denies the Motion to Remand, in whole or in part, the Parties agree to submit a Discovery Plan and Scheduling Order within thirty (30) days after entry of the Court's order on the Motion to Remand.
As no other recently added Defendants have filed Answers in this action, no other parties are affected by this Stipulation and Order.
For the foregoing reasons, the Parties respectfully suggest that good cause exists to grant the Parties' stipulated stay of discovery. The undersigned represent this stipulation is not intended for purposes of delay. If the Court deems it useful, the Parties are prepared to conduct a hearing on this stipulated request pursuant to LR 78-1.
Dated this 2nd day of October, 2019. Dated this 2nd day of October, 2019.
EGLET ADAMS ASHCRAFT & BARR | LLP
/s/ Robert M. Adams, Esq. /s/ Jeffrey F. Barr, Esq.
ROBERT T. EGLET, ESQ. JEFFREY F. BARR, ESQ.
Nevada Bar No. 3402 Nevada Bar No. 7269
ROBERT M. ADAMS, ESQ. 2300 West Sahara Avenue, Suite 900
Nevada Bar No. 6551 Las Vegas, Nevada 89102
ERICA D. ENTSMINGER, ESQ. Counsel for Defendant Aida Maxsam
Nevada Bar No. 7432
400 S. 7th Street, 4th Floor
Las Vegas, NV 89101
-and-
STEVEN B. WOLFSON, ESQ.
Nevada Bar No. 1565
District Attorney
200 E. Lewis Ave
Las Vegas, NV 89101
Counsel for Plaintiff Clark County
IT IS SO ORDERED.
