Pauluk et al v. Clark County Health District

Filing 242

ORDER Granting 241 Stipulation for Extension of Time re Discovery (Second Request). Proposed Joint Pretrial Order due by 10/19/2018. Signed by Judge Richard F. Boulware, II on 10/8/2018. (Copies have been distributed pursuant to the NEF - MR)

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BROCK K. OHLSON, ESQ.
Nevada Bar No. 12262
BROCK K. OHLSON PLLC
6060 Elton Avenue
Las Vegas, NV 89107
[phone] Telephone
[phone] Fax
E-Mail: [e-mail]
A. J. SHARP, ESQ.
Nevada Bar No. 11457
SHARP LAW CENTER
11700 West Charleston Boulevard
Suite 234
Las Vegas, NV 89135
[phone] Telephone
E-Mail: [e-mail]

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DISTRICT OF NEVADA

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Attorneys For Plaintiffs

UNITED STATES DISTRICT COURT

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CHRISTOPHER D. CAZARES, ESQ.
(Nevada pro hac vice application pending)
Arizona Bar No. 034270
CAZARES LAW, PLLC
P.O. Box 343
Sierra Vista, AZ 85636-0343
[phone] Telephone
[phone] Fax
E-Mail: [e-mail]
(Nevada local counsel)
BROCK K. OHLSON, ESQ.
Nevada Bar No. 12262
BROCK K. OHLSON PLLC
6060 Elton Avenue
Las Vegas, NV 89107

WENDY J. PAULUK, Psy.D.,
individually; WENDY PAULUK, Psy. D.
as Personal Representative of the ESTATE
OF DANIEL PAULUK; JAIME L.
PAULUK; and CHRISSY J. PAULUK,

CASE NO.: 2:07-cv-1681-RFB-VCF
STIPULATION TO EXTEND TIME
TO FILE JOINT PRETRIAL ORDER
[SECOND REQUEST]

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Plaintiffs,

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vs.

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CLARK COUNTY HEALTH DISTRICT;
GLENN SAVAGE, in both his individual
and official capacities; EDWARD
WOJCIK, in both his individual and official
capacities; DOES I through X; DOES XI
through XX; and ROE CORPORATIONS
XXI through XXX, inclusive,

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Defendants.

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COME NOW PLAINTIFFS WENDY J. PAULUK, individually and as Personal

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Representative of the ESTATE OF DANIEL PAULUK; JAIME L. PAULUK; and CHRISSY J.

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PAULUK, by and through their counsel of record, BROCK OHLSON, ESQ. of BROCK K.

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OHLSON PLLC, CHRISTOPHER D. CAZARES, ESQ. of CAZARES LAW FIRM, and A. J.

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SHARP, ESQ. of SHARP LAW CENTER, and Defendant CLARK COUNTY HEALTH

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DISTRICT, by and through its counsel of record, Walter L. Cannon, Esq. and Peter M. Angulo,

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Esq. of OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI LLP, and stipulate,

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subject to this Court’s approval, to extend the time for filing of the parties’ Joint Pretrial order

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by 14 days, through October 19, 2018. This is the parties’ second request for extension.

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This Court previously ordered that the parties file the Joint Pretrial Order on or before

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October 5, 2018. Docket Filing #238. The parties have made significant progress on their

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respective portions. However, the parties were prevented from meeting and conferring

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regarding the final joint document when Plaintiffs’ counsel CHRISTOPHER D.

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CAZARES, ESQ. was unexpectedly hospitalized in Los Angeles and required to travel

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back to Arizona to consult with his primary care physician and a cardiologist.

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Declaration of Christopher D. Cazares, Esq., infra.

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See

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DECLARATION OF CHRISTOPHER D. CAZARES, ESQ.
IN SUPPORT OF STIPULATION TO EXTEND TIME
TO FILE JOINT PRETRIAL ORDER [SECOND REQUEST]

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1.

I am an attorney duly licensed to practice law in the State of Arizona, admitted to

practice pro hac vice in this matter as counsel of record for Plaintiffs. Docket Filing #240.
2.

This Declaration is made in support of the parties’ Stipulation To Extend Time

To File Joint Pretrial Order [Second Request].
3.

The parties have communicated and cooperated in anticipation of filing the Joint

Pretrial Order by October 5, 2018, the date set by this Court in its Order on the parties prior
Stipulation. Docket Filing #238. As the parties were finalizing their respective portions of this
document, Defense counsel and I had agreed to meet and confer.
4.

On October 1-2, 2018, while in Los Angeles, California, I was hospitalized with

severe chest pains. This episode prevented me from returning to Las Vegas, requiring me
instead to travel back to Sierra Vista, Arizona, in order to see my primary care physician on

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October 4, 2018, to obtain a referral to a cardiologist. As a result of the both the hospitalization

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and the travel back to Arizona, Plaintiffs’ counsel were unable to finalize Plaintiffs’ portion of

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the JPTO or to meet and confer with Defense counsel on October 4, 2018.

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5.

Because of this event, Defense counsel and I were prevented from meeting and

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conferring as planned, and the parties are therefore unable to submit a Joint Pretrial Order on
October 5, 2018.
I declare under penalty of perjury that the foregoing is true and correct.

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/s/ Christopher D. Cazares

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CHRISTOPHER D. CAZARES

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The parties aver that this extension is requested in good faith and not for purposes of

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delay, and respectfully request that this Court extend the Joint Pretrial Order deadline to

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October 19, 2018.

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IT IS SO STIPULATED.

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DATED the 5th day of October, 2018.

DATED the 5th day of October, 2018.

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SHARP LAW CENTER

OLSON, CANNON, GORMLEY,
ANGULO & STOBERSKI LLP

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/s/ A. J. Sharp

/s/ Walter R. Cannon

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A. J. Sharp
11700 West Charleston Boulevard
Suite 234
Las Vegas, NV 89135
Attorney for Plaintiffs

Walter R. Cannon, Esq.
Peter M. Angulo, Esq.
9950 West Cheyenne Avenue
Las Vegas, NV 89129
Attorneys for Defendant
Clark County Health District

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ORDER
IT IS SO ORDERED.
October,
8th
Dated this _____ day of ______________________, 2018.

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__________________________

___________________________________
RICHARD F. BOULWARE,
UNITED STATES DISTRICT JUDGE II

United States District Court

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