Opinion
2:16-cv-02539-JAD-DJA
02-01-2023
DREE ANN CELLEMME, Plaintiff, v. MERRICK GARLAND, in his official capacity as Attorney General of the United States, Defendant.
GARMAN TURNER GORDON LLP JASON M. FRIERSON DYLAN T. CICILIANO VIRGINIA T. TOMOVA
GARMAN TURNER GORDON LLP
JASON M. FRIERSON
DYLAN T. CICILIANO
VIRGINIA T. TOMOVA
STIPULATION AND ORDER TO EXTEND CERTAIN DISCOVERY DEADLINES (SIXTH REQUEST)
Pursuant to LR IA 6-1 and LR 26-3, the parties request a 150-day extension of certain discovery deadlines as, and for the reasons, set forth below. This stipulation is filed at least 21 days before the earliest deadline to be extended (close of discovery). The purpose for the requested extension is the parties' good faith intention to mediate this case. This is the sixth request for an extension of the discovery schedule.
DISCOVERY COMPLETED
The parties have completed the following disclosures and discovery:
Defendant served Initial Disclosures of Witnesses and Documents and three supplement thereto.
Plaintiff served Initial Disclosures of Witnesses and Documents and one supplement thereto.
Plaintiff served Discovery Request, First Supplemental Discovery Request For Production of Documents, Second Supplemental Discovery Request for Production of Documents, and Defendant responded to them.
Defendant served first and second sets of Requests for Production and Interrogatories, and Plaintiff responded to Defendant's second sets of discovery requests.
On July 31, 2017, Defendant took the Deposition of Officer Roque Martinez.
DISCOVERY REMAINING
Plaintiff and Defendant intend to depose the Parties, their representatives, and any other percipient witnesses regarding the allegations in this case. Based on the outcome of these depositions, the parties may need to send additional written discovery.
WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED
The parties agreed that it will be beneficial to try to resolve this case through mediation and are currently looking into possible mediators and dates to get the mediation scheduled. In the event the mediation is not successful, the parties will need the time to complete the remaining discovery. This request is made in good faith, not for the purpose of delay.
EXTENSION OF THE DISCOVERY PLAN AND SCHEDULING ORDER
The following table sets forth the current deadlines and the proposed extended deadlines that are the subject of this stipulated request:
SCHEDULED EVENT
CURRENT DEADLINE
PROPOSED DEADLINE
Discovery Cutoff
03/17/2023
08/18/2023
Dispositive Motions
04/14/2023
09/18/2023
Proposed Joint Pretrial Order
05/12/2023
If dispositive motions were filed, the deadline for the Proposed Joint Pretrial Order would be deferred until 30 days after the Court rules on the dispositive motions.
This request for an extension of time is not sought for any improper purpose including delay.
IT IS SO ORDERED: