JOINT AND UNOPPOSED MOTION TO EXTEND DISPOSITIVE MOTION DEADLINE TO FEBRUARY 10, 2020

(Third Request)1

DANIEL J. ALBREGTS, Magistrate Judge.

Defendants Lawrence Dennison, City of Reno, Donald Ashley and Clarence Lewis, by and through undersigned counsel, respectfully move the Court, to allow the date for the dispositive motion deadline to be extended from February 1, 2020 (a Saturday) (ECF No. 199) to February 10, 2020 (a Monday). As set forth below, good cause exists for such an extension in accordance with LR IA 6-1.

Background Information

This is a 42 U.S.C. § 1983 action, with ancillary state claims, stemming from allegations that the Defendants violated Plaintiff's civil rights by coercing a confession to a 1976 Reno murder and fabricating evidence, resulting in the imprisonment of Plaintiff for approximately 35 years. In 2015, Plaintiff's conviction was set aside, and the District Attorney dismissed the murder charge against her.

The parties have completed all discovery2 except for the Plaintiff and Defendants' psychological experts, Doctors Good and Saldanha, respectively, who will be deposed in San Francisco on January 30 and 31, 2020. (See, ECF #199).

Reasons For The Extension Request

Dr. Good, who will be deposed in San Francisco the afternoon of Thursday, January 30, 2020, is both a liability and damages expert for Plaintiff and subject to the stipulations previously entered concerning the timing and disclosure of his testimony (See id.). As a liability expert, Defendants believe Dr. Good's testimony may be applicable to dispositive motions. Defense counsel from Shreveport, Louisiana, and Plaintiff's counsel from Seattle, Washington, but in Chicago for an appellate argument on January 28, 2020, will be traveling to and from San Francisco for Dr. Good's deposition (and Dr. Saldanha on January 31). Currently, the dispositive motion deadline is Saturday, February 1, 2020. It is not likely the parties could obtain the transcript of Dr. Good's deposition before the dispositive motion deadline, let alone review and incorporate it in a motion, particularly given travel considerations. Thus, in order to [1] allow time to obtain the transcript, [2] make dispositive motions due on a weekday, when attorney and court staff is available3, and [3] allow for travel, Defendants respectfully seek to extend the dispositive motion deadline to February 10, 2020.

Plaintiff does not oppose this request.

Proposed Dispositive Motion Deadline

IT IS SO ORDERED.