MOTION FOR ENLARGEMENT OF TIME FOR DEFENDANT LAVERT TAYLOR TO RESPOND TO INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SECOND REQUEST)

VALERIE P. COOKE, Magistrate Judge.

Defendants James Brill, Cheryl Burson, Michael Maxfield, Jeffrey Patterson, Lavert Taylor, and Brian Williams, by and through counsel, Adam Paul Laxalt, Attorney General of the State of Nevada, and Erin L. Albright, Deputy Attorney General, hereby file this motion for enlargement of time for Defendant Lavert Taylor to Respond to Interrogatories and Request for Production of Documents.

This motion is based on the following Memorandum of Points and Authorities and all papers and pleadings on file herein.

MEMORANDUM OF POINTS AND AUTHORITIES

I. INTRODUCTION

Defendant Lavert Taylor requests this Court enlarge the time to respond to Plaintiff's discovery request to August 13, 2018.

II. RELEVANT FACTS

Plaintiff served Defendant Lavert Taylor with "Plaintiff's Interrogatories and Request for Production of Documents Directed to Defendant Lavert Taylor" on May 8, 2018. The discovery requests seek information from June 5, 2007.

The documents necessary to respond to the discovery requests, if any, are in storage. A request for the documents has been made; however, the documents will not be provided to Defendant Lavert Taylor before the deadline to respond to the discovery requests.

III. ARGUMENT

The Court may enlarge the period of time for an act to be performed after the expiration of the specified period of time in which the act was to be done where the failure to act was the result of excusable neglect. NRCP 6(b)(2). The Supreme Court has used the following guideposts for determining whether neglect is "excusable:" the danger of prejudice to the [non-movant], the length of the delay and its potential impact on judicial proceedings, the reason for the delay, including whether it was within the reasonable control of the movant, and whether the movant acted in good faith." Pioneer Inv. Svcs. Co. v. Brunswick Assocs. Ltd. P'ship, 507 U.S. 380, 395 (1993) (footnote omitted) (citing In re Pioneer Inv. Svcs. Co., 943 F.2d 673, 677 (6th Cir. 1991)).

Defendant Lavert Taylor asserts good cause exists to extend the deadline for him to respond to Plaintiff's discovery requests. The time to respond to the discovery requests has not expired. Defendant Lavert Taylor seeks an enlargement of time to file to respond to Plaintiff's discovery requests because the documents necessary to respond to the requests, if any, are in storage and will not be provided to defendant prior to the deadline for his discovery responses. Therefore, Defendant Lavert Taylor respectfully requests this Court extend the deadline to respond to Plaintiff's discovery requests to August 13, 2018. The requested extension is done in good faith and not made for the purposes of delay or to prejudice Plaintiff.

IV. CONCLUSION

Based on the foregoing, Defendant Lavert Taylor respectfully requests this Court enlarge the time to for him to respond to Plaintiff's discovery requests to August 13, 2018.

IT IS SO ORDERED.