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, 1 Case No. 3:20-cv-00263-CLB Plaintiff, 12 MOTION FOR EXTENSION OF TIME Vv. TO RESPOND TO PLAINTIFF’S 13 MOTION FOR AN ORDER SORICH, et al., COMPELLING DISCOVERY 14 (ECF NO. 25) Defendants. (Third 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, || and 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 is the third 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. Counsel || for Defendants met with Wilder at NNCC on May 17, 2022 to review and discuss discovery |/issues, available documentation and media, and possible resolution of this case. Wilder 14 Defendants agreed to a two-week extension for Defendants’ response to the Motion up ||to and including May 31, 2022, to provide time for the parties to attempt to resolve the || pending discovery dispute or settle the case. Defendants now request this Court extend || Defendants’ deadline to submit a response to the Motion from May 17, 2022 to May 31, || 2022.

19 Therefore, the Defendants request an extension of time to file their response to Wilder’s || Motion, which would then be due on May 31, 2022.

21 DATED this 17th day of May 2022.

22 AARON D. FORD Attorney General 23 No further extensions of time will be granted.

24 By: /s/ David A. Bailey IT IS SO ORDERED. DAVID A. BAILEY, Bar No. 13661 25 Deputy Attorney General Datec: y 18, 2022 26 ‘ Attorneys for Defendants UNITED STATES MAGISTRATE JUDGE 1 CERTIFICATE OF CONFERENCE 2 Undersigned Counsel for Defendants certifies that he and Plaintiff Christopher || Wilder conducted an in-person meet-and-confer on May 17, 2022, regarding discovery in 4 matter, extending the time for which Defendants would have to respond to Wilder’s ||Motion, and a proposed settlement. Wilder is not opposed to the extension of time || Defendants seek herein to respond to the Motion. /s/ David A. Bailey 8 DAVID A. BAILEY, Bar No. 13661 1 CERTIFICATE OF SERVICE 2 I certify that Iam an employee of the Office of the Attorney General, State of Nevada, 3 that on this 17th day of May 2022, I caused to be served, a true and correct copy of the ||foregoing, MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S 5 MOTION FOR AN ORDER COMPELLING DISCOVERY (ECF NO. 25) (Third || Request), by U.S. District Court CM/ECF Electronic Filing on: 7 Christopher Wilder, #83600 8 Northern Nevada Correctional Center P.O. Box 7000 9 Carson City, NV 89702 [email protected] 1 /s/ Karen Easton An employee of the Office 12 of the Attorney General