STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

CARL W. HOFFMAN, Magistrate Judge.

IT IS HEREBY STIPULATED by and between Plaintiffs LOUIS AND DEBBY ROCK, by and through their counsel of record, JOSEPH TROIANO, ESQ., of EGLET PRINCE, Defendant ROADSAFE TRAFFIC SYSTEMS, INC. by and through their counsel of record, JASON C. FOULGER, ESQ., of CISNEROS & MARIAS, Defendant NINYO & MOORE, GEOTECHNICAL DBA CONSULTANTS DBA NINYO & MOORE GEOTECHNICAL & ENVIROMENTAL SCIENCES CONSULTANTS by and through their counsel of record, MICHAEL R. HALL, ESQ., of HALL JAFFE & CLAYTON, LLP., that discovery in this matter shall be extended for the limited purpose of completing the discovery described herein. Pursuant to Local Rules ("LR") 6-1, 6-2, 7-1, and 26-4, the parties offer the following in support of their stipulation to extend discovery:

I.

DISCOVERY COMPLETED TO DATE

Plaintiffs served Defendants with the following discovery to date:

1. Plaintiffs' Initial NRCP 16.1 disclosures and Four (4) Supplements thereto;

2. Plaintiffs' Responses to Defendant's Requests for Production, Requests for Admissions and Interrogatories; and

3. Plaintiffs' Requests for Production, Requests for Admissions and Interrogatories to Defendants;

4. Plaintiffs' Expert Disclosure and Supplemental NRCP 16.1 (a)(3) Pre-Trial Disclosures and Two (2) Supplements thereto.

Defendant Roadsafe Traffic Systems, Inc., served Plaintiffs with the following discovery to date:

1. Defendant's Initial NRCP 16.1 disclosure;

2. Defendant's Requests for Production of Documents, Interrogatories and Requests for Admissions to Plaintiff; and

3. Defendant's Answers to Plaintiff's Requests for Production and Interrogatories to Plaintiff.

1. Defendant's Initial NRCP 16.1 disclosures and Three (3) Supplements thereto;

2. Defendant's Requests for Production of Documents, Interrogatories and Requests for Admissions to Plaintiff; and

3. Defendant's Answers to Plaintiff's Requests for Production and Interrogatories to Plaintiff.

II.

DEPOSITIONS TAKEN TO DATE

1. Deposition of Michael Thompson taken on October 30, 2017;

2. Deposition of Officer Shane R. Witham taken on November 21, 2017;

3. Deposition of Naik Banavathu taken on January 23, `.

III.

DISCOVERY THAT REMAINS TO BE COMPLETED

1. Deposition of Rathna Mothkuri scheduled for February 5, 2018;

2. Deposition of Defendant's NRCP 30(b)(6) witness(es);

3. Depositions of the parties respective experts;

4. Depositions of parties before and after witnesses; and

The Parties anticipate that they may need to conduct other forms of discovery, though not specifically delineated herein, and anticipate doing so only on an as-needed basis.

IV.

REASONS DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS AND NEEDS TO BE EXTENDED

Although the Parties have diligently been working on this matter there are still depositions in this matter that need to be completed. Also, parties have agreed to mediate this matter and we are working on scheduling the same. In addition, our expert, Patrick Altvater, had an unexpected medical issue.

V.

CURRENT DISCOVERY DEADLINES AND TRIAL DATE

VI.

PROPOSED DISCOVERY DEADLINES AND TRIAL DATE

ORDER

IT IS SO ORDERED.