Joseph Ricci v. James Scally, et al.

• Court: District Court, D. Nevada
• Decided: October 1, 2025
• Docket: 2:23-cv-02089
• Status: Unknown

Opinion

1 |} AARON D. FORD Attorney General 2 || VICTORIA C. COREY, (Bar No. 16364) Senior Deputy Attorney General 3 || State of Nevada Office of the Attorney General 4 State of Nevada Way, Ste. 100 Las Vegas, Nevada 89119 5 ||(702) 486-0849 (phone) (702) 486-3768 (fax) 6 || Email: vcorey@ag.nv.gov 7 || Attorneys for Defendant Jaymie Cabrera 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 || JOSEPH RICCI, Case No. 2:23-cv-02089-RFB-BNW 12 Plaintiff, STIPULATION AND PROPOSED 138 v. ORDER TO EXTEND DISCOVERY [ECF NO. 22] 14 || JAMES SCALLY, e al., First Request 15 Defendant. 16 17 Plaintiff Joseph Ricci (Plaintiff), pro se, and Defendant Jaymie Cabrera, by and 18 || through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Victoria C. 19 || Corey, Senior Deputy Attorney General, respectfully submit the following Stipulation to 20 || Extend Discovery Deadlines outlined in ECF No. 22 at 6:12-20. This is the parties first 21 || request. 22 I DISCOVERY COMPLETED 23 1. Defendant’s Initial Disclosures 24 2. Interrogatories to Defendant and Defendant’s response 25 3. Request for Production of Documents to Defendant and Defendant’s response 26 4. Interrogatories Set 2 to Defendant 27 5. Request for Production of Documents Set 2 to Defendant 28 ///

DISCOVERY THAT REMAINS TO BE COMPLETED 2 1. Defendant’s response to Interrogatories Set 2 3 2. Defendant’s response to Request for Production Set 2 4 3. Other Written Discovery that may come from said responses 5 REASONS THE REMAINING DISCOVERY WAS NOT COMPELTED 6 WITHIN THE TIME LIMITS SET BY THE DISCOVERY PLAN 7 On or around August 22, 2025, the State of Nevada began experiencing a statewide 8 network outage, which continued until very recently, September 26, 2025. The statewide 9 || network outage blocked the Office of the Attorney General’s access to its case management 10 || software and case files. Due to this, counsel for Defendants was unable to provide Plaintiff 11 || with responses to his discovery requests, as well as the providing him with copies of the 12 || discovery that had already occurred in this matter. 13 The parties spoke on September 19, 2025, and agreed that a continuance of discovery 14 || was needed and necessary due to the network outage, which was of no fault of either party. 15 /// 16 /// 17 18 19 /// 20 21 22 23 24 25 26 27 28 || ///

1 PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY 2 The parties jointly propose the following discovery plan, which would allow for an 3 || additional 60 days to complete discovery: 4 Current Date Proposed Date 5 Amend Pleadings October 10, 2025 November 21, 2025 6 Discovery Cut-off: September 22, 2025 November 21, 2025 7 Dispositive Motions: October 22, 2025 December 22, 2025 8 Joint Pretrial Order: November 21, 2025 January 20, 2026! 9 10 This first request for an extension of the current discovery deadlines is made by the 11 || parties in good faith and not for the purpose of delay. 12 13 || DATED this 30th day of September, 2025. DATED this 30th day of September, 2025. 14 AARON D. FORD 15 Attorney General 16 . . By; /s/ Joseph Ricci By: /s/ Victoria C. Corey 17 || JOSEPH RICCI VICTORA C. COREY (Bar No. 16364) 18 || Plaintiff, pro se Deputy Attorney General 19 Attorneys for Defendant 20 ORDER 21 IT IS SO ORDERED. 22 le Are, 23 UNITED STATES MAGISTRATE JUDGE 24 DATE: October 1, 2025 25 26 27 28 1 Or 30 days following the entry of the Court’s ruling on a dispositive motion.