Joseph Ricci v. James Scally, et al.

Opinion

} AARON D. FORD Attorney General VICTORIA C. COREY, (Bar No. 16364) Senior Deputy Attorney General State of Nevada Office of the Attorney General State of Nevada Way, Ste. 100 Las Vegas, Nevada 89119 (702) 486-0849 (phone) (702) 486-3768 (fax) Email: vcorey@ag.nv.gov Attorneys for Defendant Jaymie Cabrera JOSEPH RICCI, Case No. 2:23-cv-02089-RFB-BNW Plaintiff, STIPULATION AND PROPOSED 138 v. ORDER TO EXTEND DISCOVERY [ECF NO. 22] JAMES SCALLY, e al., First Request Defendant. Plaintiff Joseph Ricci (Plaintiff), pro se, and Defendant Jaymie Cabrera, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Victoria C. Corey, Senior Deputy Attorney General, respectfully submit the following Stipulation to Extend Discovery Deadlines outlined in ECF No. 22 at 6:12-20. This is the parties first request. 1. Defendant’s Initial Disclosures 2. Interrogatories to Defendant and Defendant’s response 3. Request for Production of Documents to Defendant and Defendant’s response 4. Interrogatories Set 2 to Defendant 5. Request for Production of Documents Set 2 to Defendant ///

DISCOVERY THAT REMAINS TO BE COMPLETED 1. Defendant’s response to Interrogatories Set 2 2. Defendant’s response to Request for Production Set 2 3. Other Written Discovery that may come from said responses REASONS THE REMAINING DISCOVERY WAS NOT COMPELTED On or around August 22, 2025, the State of Nevada began experiencing a statewide network outage, which continued until very recently, September 26, 2025. The statewide network outage blocked the Office of the Attorney General’s access to its case management software and case files. Due to this, counsel for Defendants was unable to provide Plaintiff with responses to his discovery requests, as well as the providing him with copies of the discovery that had already occurred in this matter. The parties spoke on September 19, 2025, and agreed that a continuance of discovery was needed and necessary due to the network outage, which was of no fault of either party. /// /// /// ///

PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY The parties jointly propose the following discovery plan, which would allow for an additional 60 days to complete discovery: Current Date Proposed Date Amend Pleadings October 10, 2025 November 21, 2025 Discovery Cut-off: September 22, 2025 November 21, 2025 Dispositive Motions: October 22, 2025 December 22, 2025 Joint Pretrial Order: November 21, 2025 January 20, 2026! This first request for an extension of the current discovery deadlines is made by the parties in good faith and not for the purpose of delay. DATED this 30th day of September, 2025. DATED this 30th day of September, 2025. Attorney General . . By; /s/ Joseph Ricci By: /s/ Victoria C. Corey JOSEPH RICCI VICTORA C. COREY (Bar No. 16364) Plaintiff, pro se Deputy Attorney General Attorneys for Defendant ORDER le Are, UNITED STATES MAGISTRATE JUDGE DATE: October 1, 2025 1 Or 30 days following the entry of the Court’s ruling on a dispositive motion.