Wilder v. Sorich

1 || AARON D. FORD Attorney General || DAVID A. BAILEY, Bar No. 13661 Deputy Attorney General State of Nevada N. Carson Street || Carson City, Nevada 89701-4717 Tel: (775) 684-1163 E-mail: [email protected] || Attorneys for Defendants George Sorich and Paul Samsel 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA |} CHRISTOPHER WILDER, Case No. 3:20-cv-00263-CLB 11 Plaintiff, 12 MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S || SORICH, et al., MOTION FOR AN ORDER COMPELLING DISCOVERY 14 Defendants. (ECF NO. 25) (Second Request) 16 Defendants George Sorich and Paul Samsel, by and through counsel, Aaron D. Ford, || Attorney General of the State of Nevada, and David A. Bailey, Deputy Attorney General, || request this Court grant an extension of time to respond to Plaintiff Christopher Wilder’s || Motion for an Order Compelling Discovery (ECF No. 25) (“Motion”). This request is made || and based on the attached points and authorities, the papers and pleadings on file herein, 21 such other and further information as this Court may deem appropriate.

22 MEMORANDUM OF POINTS AND AUTHORITIES 23 Courts have inherent powers to control their dockets, see Ready Transp., Inc. v. AAR || Mfg, Inc., 627 F.3d 402, 404 (citations omitted), and to “achieve the orderly and expeditious || disposition of cases.” Chambers v. NASCO, Inc., 501 U.S. 32, 48 (1991) “Such power is ||indispensable to the court’s ability to enforce its orders, manage its docket, and regulate ||insubordinate [] conduct. Id. (citing Mazzeo v. Gibbons, No. 2:08—cv01387-—RLH—PAL, 2010 || WL 3910072, at *2 (D.Nev. 2010)).

1 || LR IA 6-1 discusses requests for continuances. The rule states: 2 (a) A motion or stipulation to extend time must state the reasons for the extension requested and must inform the court of all 3 previous extensions of the subject deadline the court granted. (Examples: “This is the first stipulation for extension of time to 4 file motions.” “This is the third motion to extend time to take discovery.”)

6 This 1s the second request, and is requested for good cause. Defendants are finalizing certain discovery responses that will be sent to Wilder that should narrow, if not eliminate, ||the issues this Court would need to consider from Wilder’s Motion. Counsel for the || Defendants met-and-conferred with Wilder on April 22, 2022 and negotiated an extension 10 time to respond to the Motion so Wilder could review Defendants’ responses and || produced documents with a next meet-and-confer call scheduled for May 12, 2022. Wilder ||and Defendants agreed to an extension for Defendants’ response to the Motion up to and ||including May 17, 2022, to provide time for the parties to attempt to resolve the pending || discovery dispute. Defendants now request this Court extend Defendants’ deadline to 15 submit a response to the Motion from April 26, 2022 to May 17, 2022.

16 Therefore, the Defendants request an extension of time to file their response to Wilder’s || Motion, which would then be due on May 17, 2022.

18 DATED this 26th day of April 2022.

19 AARON D. FORD Attorney General 21 By: /s/ David A. Bailey DAVID A. BAILEY, Bar No. 13661 22 Deputy Attorney General 23 Attorneys for Defendants IT IS SO ORDERED.

Dated: Apri 2022 26 RS] J 27 Cl V0 28 UNITED STATES MAGISTRATE JUDGE 1 CERTIFICATE OF CONFERENCE 2 Undersigned Counsel for Defendants certifies that he and Plaintiff Christopher || Wilder conducted a telephonic meet-and-confer on April 22, 2022, regarding discovery in 4 matter as well as extending the time for which Defendants would have to respond to || Wilder’s Motion. Wilder is not opposed to the extension of time Defendants seek herein to || respond to the Motion. /s| David A. Bailey 7 DAVID A. BAILEY, Bar No. 13661 11 CERTIFICATE OF SERVICE 12 I certify that Iam an employee of the Office of the Attorney General, State of Nevada, || and that on this 26th day of April 2022, I caused to be served, a true and correct copy of the || foregoing, MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S || MOTION FOR AN ORDER COMPELLING DISCOVERY (ECF NO. 25) (Second || Request), by U.S. District Court CM/ECF Electronic Filing on: W Christopher Wilder, #83600 18 Northern Nevada Correctional Center P.O. Box 7000 19 Carson City, NV 89702 [email protected] 91 /s/ Karen Easton An employee of the Office 99 of the Attorney General