Opinion
2:22-cv-00014-CDS-DJA
04-19-2022
AARON D. FORD Attorney General MICHAEL ROWE Plaintiff in proper person CARRIE L. PARKER ' Deputy Attorney General NV Bar No. 10952 CAMERON P. VANDENBERG Chief Deputy Attorney General NV Bar No. 4356 Office of the Attorney General Defendants State of Nevada and Brian Sandoval
AARON D. FORD Attorney General
MICHAEL ROWE Plaintiff in proper person
CARRIE L. PARKER '
Deputy Attorney General
NV Bar No. 10952
CAMERON P. VANDENBERG
Chief Deputy Attorney General
NV Bar No. 4356
Office of the Attorney General
Defendants State of Nevada and Brian Sandoval
STIPULATION TO EXTEND DEADLINE FOR RESPONSE TO MOTION TO STAY DISCOVERY (ECF NO. 20)
Defendants State of Nevada, erroneously named as “The State of Nevada (Tort Claims Act)” (“the State”) and Brian Sandoval (collectively with the State, “Defendants”), by and through counsel, and Plaintiff Michael Rowe in proper person, pursuant to LR lA 6-1, LRIA 6-2, hereby stipulate to extend the deadline for Plaintiff's response to motion to stay discovery (ECF No. 20) to Monday, April 25, 2022.
This is the first request for an extension of time for Plaintiff to file a response to the Motion to Stay Discovery, which was filed on March 28, 2022. The deadline was Thursday, April 14, 2022. However, this request is based on good cause and is not for purpose of delay.
1. On March 28, 2022, Defendants filed the Motion to Stay and supporting documents. ECF Nos. 20, 21, 21-1, 21-2.
2. On March 28, 2022, Defendants mailed to Plaintiffs last known address copies of that day's filings, including the Motion to Stay and supporting documents (ECF Nos. 20, 21, 211, 21-2) as well as Mr. Sandoval's Motion to Dismiss (ECF No. 17).
3. On March 28, 2022, Defendants also emailed to Plaintiff copies of that day's filings, including the Motion to Stay and supporting documents (ECF Nos. 20, 21, 21-1, 21-2) as well as Mr. Sandoval's Motion to Dismiss (ECF No. 17).
4. On April 1, 2022, the Court granted in part and denied in part the parties' Discovery Plan and Scheduling Order. ECF No. 24.
5. On April 4, 2022, the Court filed notices of returned mail related to Minute Orders ECF Nos. 12, 23 that the Court had mailed to Plaintiffs last known address. ECF Nos. 26, 27. Thereafter, Defendants contacted Plaintiff to confirm his address. Plaintiff responded that his address had not changed, and the Post Office had made an error.
6. On April 11, 2022, Plaintiff filed his Opposition to Mr. Sandoval's Motion to Dismiss. ECF No. 28.
7. On the afternoon of Friday, April 15, 2022, Defendants learned that the envelope containing the Motion to Stay and supporting exhibits, which Defendants had mailed to Plaintiffs last known address on March 28, 2022, was returned to sender.
8. On the morning of Monday, April 18, 2022, the parties met and conferred via email.
Plaintiff stated that he had thought discovery had been set and that he intended to file a response to the Motion to Stay Discovery.
9. The parties agreed to an extension to Monday, April 25, 2022 for any response to the Motion to Stay (ECF No. 20).
Upon agreement, the parties request that this Court grant Plaintiff an extension until Monday, April 25, 2022 to file a response to the Motion to Stay (ECF No. 20). This is the first request for an extension of this deadline.
ORDER
IT IS SO ORDERED.