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Quintero v. Aranas, 3:17-cv-00066-MMD-CLB. (2019)

Court: District Court, D. Nevada Number: infdco20191209582 Visitors: 12
Filed: Dec. 03, 2019
Latest Update: Dec. 03, 2019
Summary: DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S INTERROGATORIES, REQUEST FOR ADMISSIONS, AND REQUEST FOR PRODUCTION OF DOCUMENTS (First Request) CARLA BALDWIN , Magistrate Judge . Defendant, Isidro Baca, James Dzurenda, E.K. McDaniel and Richard Snyder by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Harry B. Ward, Deputy Attorney General, hereby moves this Honorable Court for an enlargement of time to respond to Plaintiff's interrogat
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DEFENDANTS' MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S INTERROGATORIES, REQUEST FOR ADMISSIONS, AND REQUEST FOR PRODUCTION OF DOCUMENTS (First Request)

Defendant, Isidro Baca, James Dzurenda, E.K. McDaniel and Richard Snyder by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Harry B. Ward, Deputy Attorney General, hereby moves this Honorable Court for an enlargement of time to respond to Plaintiff's interrogatories, request for admissions, and second and third sets of request for production of documents.

MEMORANDUM OF POINTS AND AUTHORITIES

I. RELEVANT PROCEDURAL HISTORY

This case is a pro se civil rights action pursuant to 42 U.S.C. § 1983. (ECF No. 9 at 1.) Plaintiff, John Quintero (Plaintiff), is an inmate in the lawful custody of the Nevada Department of Corrections (NDOC". (Id.) Plaintiff sues various NDOC employees and alleges they violate his rights under the First, Eighth, and Fourteenth Amendments to the U.S. Constitution. (Id. at 3-22.)

II. LEGAL AUTHORITIES

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.

III. ARGUMENT

Defendants respectfully request a thirty (30) day extension of time out from the current deadline of December 2, 2019, to serve responses to Plaintiff's discovery requests to Defendants.

Due to the volume of information and documents requested, Defendants cannot timely answer Plaintiff's interrogatories, request for admissions, and request for production of documents. Defendants make this request in good faith, not for the purpose of unnecessary delay, and Defendants do not believe Plaintiff will be unduly prejudiced by the requested enlargement.

Additionally, the undersigned has been working with the staff in the Office of the Attorney General in an effort to meet the deadline, but unfortunately is unable to meet the deadline. Defendants submit there is good cause allowing Defendants an additional 30 days to respond to the Plaintiff's discovery requests to ensure accurate and adequate response to the discovery. Accordingly, Defendants respectfully requests this Court allow Defendants up to and including Thursday, January 2, 2020, to answer Plaintiff's interrogatories, request for admissions, and second set of request for production of documents.

IV. CONCLUSION

Wherefore, Defendant submits that there is good cause for the extension of additional time in which to respond to the discovery request. This request for an extension of time is made in good faith and not for the purpose of undue delay. Defendants respectfully requests this Court allow Defendants up to and including Thursday, January 2, 2020, to answer Plaintiff's interrogatories, request for admissions, and second set of request for production of documents.

Dated this 2nd day of December, 2019. AARON D. FORD Attorney General By: /s/Harry B. Ward HARRY B. WARD, Bar No. 11317 Deputy Attorney General Attorneys for Defendants

IT IS SO ORDERED.

Source:  Leagle

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