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Weddle v. BACA, 3:16-cv-00634-MMD-CBC. (2019)

Court: District Court, D. Nevada Number: infdco20190816779 Visitors: 16
Filed: Aug. 08, 2019
Latest Update: Aug. 08, 2019
Summary: MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY (FIRST REQUEST) CARLA BALDWIN CARRY , Magistrate Judge . Defendants David Carpenter, Pamela Feil, and Jason O'Dea, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, hereby hereby submit their Motion for Extension of Time to File Responses to Plaintiffs Discovery requests. (First Request). This Motion is based on Federal Rule of Civil Procedure 6(b)(1)(A),
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MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY (FIRST REQUEST)

Defendants David Carpenter, Pamela Feil, and Jason O'Dea, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Douglas R. Rands, Senior Deputy Attorney General, hereby hereby submit their Motion for Extension of Time to File Responses to Plaintiffs Discovery requests. (First Request). This Motion is based on Federal Rule of Civil Procedure 6(b)(1)(A), the following Memorandum of Points and Authorities, and all papers and pleadings on file in this action.

MEMORANDUM OF POINTS AND AUTHORITIES

I. ARGUMENT

Defendants respectfully request a sixty (45) day extension of time out from the current deadline (August 8, 2019) to respond to Plaintiffs Discovery in this case. Defense counsel submits that this Division has experienced a wave of recent retirements and departures. Although the Division is depleted, new Deputy Attorneys General (DAGs) should be arriving in early August to help restore normal functionality. Defense counsel respectfully requests this extension to accommodate the new arrivals and the Division during this transition period. Additionally, Counsel is preparing for a Jury Trial in front of Judge Jones which is set to commence on Monday, August 12, 2019, which is further stretching the resources of this office.

Federal Rule of Civil Procedure 6(b)(1) governs extensions of time and provides as follows:

When an act may or must be done within a specified time, the court may, for good cause, extend the time: (A) with or without motion or notice if the court acts, or if a request is made, before the original time or its extension expires; or (B) on motion made after the time has expired if the party failed to act because of excusable neglect.

Defendants' request is timely and will not hinder or prejudice Plaintiffs case, but will allow for a thorough opportunity to respond to the discovery requests. The requested sixty (45) day extension of time should permit the parties time to adequately research draft, and submit discovery in this case. Defendants assert that the requisite good cause is present to warrant the requested extension of time.

DATED this 8th day of August, 2019. AARON D. FORD Attorney General By: ________ DOUGLAS R. RANDS, Bar No. 3572 Senior Deputy Attorney General Attorneys for Defendants

IT IS SO ORDERED.

Source:  Leagle

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