Long v. The Venetian Casino Resort et al

Filing 15

ORDER Granting 13 Stipulated Discovery Plan/Scheduling Order. (Interim Status Report due by 1/14/2011, Discovery due by 3/18/2010, Motions due by 4/18/2011, Proposed Joint Pretrial Order due by 5/18/2011.) Signed by Magistrate Judge Lawrence R. Leavitt on 12/16/2010. (Copies have been distributed pursuant to the NEF - DXS)

Long v. The Venetian Casino Resort et al

Doc. 15

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DEANNA L. FORBUSH Nevada Bar No. 6646 RACHEL BICKLE-STONE Nevada Bar No. 11057 FOX ROTHSCHILD LLP 3800 Howard Hughes Parkway, Suite 500 Las Vegas, Nevada 89169 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Venetian Casino Resort UNITED STATES DISTRICT COURT DISTRICT OF NEVADA

CHRISTI M. LONG, an individual, Plaintiff, vs. THE VENETIAN CASINO RESORT, a Domestic Limited Liability Company; DOE INDIVIDUALS 1 through X inclusive; ROE BUSINESSES OR GOVERNMENTAL ENTITIES 1 through X, inclusive, Defendants.

Case No. 2:09-cv-01177-LDG-LRL

STIPULATED DISCOVERY PLAN AND SCHEDULING ORDER

Plaintiff Christie M. Long and Defendant The Venetian Casino Resort, by and through their undersigned attorneys hereby submit their Stipulated Discovery Plan and Scheduling Order in compliance with LR 26-1. 1. Initial Rule 26(f) Conference was held on August 11, 2010. Exchange of Initial Disclosures ­ Defendant Venetian Casino Resort exchanged

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23 its initial disclosures on August 13, 2010. Plaintiff will exchange her initial disclosures or before 24 December 10, 2010,
FOX ROTHSCHILD LLP
3800 Howard Hughes Parkway Suite 500 Las Vegas, Nevada 89169

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Subject of Discovery:

Discovery will be conducted regarding liability and

2 damages, if any, as alleged in Plaintiff's Complaint. 3 4. Disclosure of Electronically Stored Information: Electronically stored

4 information will be exchanged by the parties in paper or in .pdf format. However, the parties are 5 6 7 8 9 not waiving, and expressly reserve, the right to see production of electronically stored information in its native file format and/or seek metadata associated with electronic files. 5. Protection of Privileged/Trial Preparation Material: Currently, there are no issues

related to claims of privilege or of protection as trial preparation material. The parties have not reached any agreement on a procedure to assert such claims after production. 6. Discovery Deadline ­ Each party anticipates conducting discovery permissible

10 under the Federal Rules of Civil Procedure 26(b). The parties have agreed that the date by which 11 to complete discovery will be March 18, 2010. 12 13 prior to the discovery deadline. 14 8. Interim Status Report: January 14, 2011 is the last Court day to submit a joint 7. Amend Pleadings and Add Parties: Pursuant to LR 26-1(e)(2), motions to amend

the pleadings or to add parties shall be filed and served on or before December 17, 2010, 90 days

15 interim status report, 60-days prior to the discovery deadline pursuant to LR 26-3. 16 9. Expert Witness Information ­ January 14, 2011 is the last day for the parties to

17 exchange expert witness information and reports. February 14, 2010 is the last day for the 18 parties to exchange rebuttal witness information, 30 days after the initial disclosure of experts 19 20 11. 21 22 Extending Discovery ­ Any motions or stipulations to extend discovery must be received by the Court by February 25, 2011. 12. Dispositive Motions ­ dispositive motions must be filed on or before April 18, pursuant to LR 26-1(e)(3). The requirements of FRCP 26(a)(2)(B) shall apply to any such disclosures.

23 2011, 30 days after the discovery deadline pursuant to LR 26-1(e)(4). 24
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Summary Judgment ­ Unless a different time is set by the Court, any motion for
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summary judgment must be filed on or before April 18, 2011. 14. Motions in Limine ­ Pursuant to LR 16-3, motions in Limine may be filed at any

3 time up to thirty days before trial. 4 5 6 7 8 9 10 FOX ROTHSCHILD LLP 11 12 13 14 15 16 17 18 19 20 21 United States Districttrate Judge Magis Court Judge 22 23 24
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3800 Howard Hughes Parkway Suite 500 Las Vegas, Nevada 89169

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Joint Pretrial Order ­ The joint pretrial order required by LR 26-1(e)(5) shall be

filed by the parties no later than May 18, 2011, thirty days after the deadline for filing dispositive motions. In the event dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until thirty days after the decision of the dispositive motions or until further order of the Court as provided in LR 26-1(e)(5). The disclosures required by FRCP 26(a)(3), and any objections thereto, shall be included in the pretrial order as required by LR 26-1(e)(6). Respectfully submitted this 1st day of December 2010. LAW OFFICES OF PHILIP J. TRENCHAK

BY:__/s/ Deanna L. Forbush_____________ DEANNA L. FORBUSH RACHEL BICKLE-STONE 3800 Howard Hughes Parkway, Suite 500 Las Vegas, Nevada 89169 [e-mail] [e-mail] Attorneys for Venetian Casino Resort

By:___/s/ Phillip J. Trenchak____________ PHILIP J. TRENCHAK Nevada Bar No. 9924 3470 East Russell Road, Suite 215 Las Vegas, Nevada 89120 [e-mail] Attorneys for Plaintiff Christi M. Long

ORDER 16th It is so ORDERED this ___ day of December 2010.

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