Goodkin v. Phillips, Harper & Harper, LLC

Filing 9

SCHEDULING ORDER re 8 Proposed Discovery Plan/Scheduling Order. Discovery due by 3/14/2011. Motions due by 4/13/2011. Proposed Joint Pretrial Order due by 5/13/2011. Signed by Magistrate Judge Lawrence R. Leavitt on 12/3/10. (Copies have been distributed pursuant to the NEF - EDS)

Goodkin v. Phillips, Harper & Harper, LLC

D

Doc.

1 2 3 4 5 6 7 8 9 10 11
COGBURN LAW OFFICES

COGBURN LAW OFFICES ANDREW L. REMPFER, ESQ. Nevada Bar No. 8628 [e-mail] JAMIE S. COGBURN, ESQ. Nevada Bar No. 8409 9555 S. Eastern Ave., Suite 280 Las Vegas, Nevada 89123 Tel: [phone] Fax: [phone] Attorneys for MARY GOODKIN UNITED STATES DISTRICT COURT DISTRICT OF NEVADA MARY GOODKIN, Plaintiff, v s. PHILLIPS, HARPER & HARPER, LLC, a limited liability company, Defendant. SUBMITTED IN COMPLIANCE WITH LR 26-1(e) Plaintiff Mary Goodkin ("Plaintiff"), by and through her counsel of record file her Discovery Plan and Scheduling Order pursuant to Fed. R. Civ. P. 26 and Local Rule 26-1(e).1 PLAINTIFF'S PROPOSED SCHEDULE 1. Fed. R. Civ. P. 26(a) Initial Disclosure: Plaintiff will exchange initial disclosures no later than December 8, 2010, or fourteen days after Plaintiff submitted this report pursuant to LR 26-1(d). No changes are necessary in the form or requirement for disclosures under Fed. R. Civ. P. 26(a). 2. Estimate of Time Required for Discovery: Discovery will take 180 days from September 15, 2010, which is the date Defendant Phillips, Harper and Harper, LLC filed their Motion to Dismiss. completed not later than March 14, 2011.
1

Case No: 2:10-CV-01223-JCJ-LRL PLAINTIFF'S PROPOSED DISCOVERY PLAN AND SCHEDULING ORDER

12
9555 S. Eastern Ave., Suite 280 Las Vegas, Nevada 89123 [phone] FAX: [phone]

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

All discovery must be

Plaintiff made two attempts to contact Defendant to schedule the Fed. R. Civ. P. 26(f) conference, and never received a response. Accordingly, Plaintiff files her own proposed plan and scheduling order.

Page 1 of 3

ockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11
COGBURN LAW OFFICES

3. Amending the Pleadings and Adding Parties: Unless stated herein or ordered by the Court, the date for filing motions to amend the pleadings or to add parties shall not be later than 90 days prior to the discovery cut-off date, and therefore not later than December 14, 2010. 4. Fed. R. Civ. P. 26(a)(2) Disclosures (Experts): In accordance with Fed. R. Civ. P. 26(a)(2), disclosures identifying experts shall be made 60 days prior to the discovery cut-off date, and therefore not later than January 13, 2010, and disclosures of rebuttal experts shall be made 30 days after the initial disclosure of experts, and therefore not later than February 12, 2010. 5. Dispositive Motions: The parties shall file dispositive motions 30 days after the discovery cut-off date, and therefore not later than April 13, 2011. 6. Pretrial Order: If no dispositive motions are filed, and unless otherwise ordered by this Court, the Joint Pretrial Order shall be filed 30 days after the date set for filing dispositive motions, and therefore not later than May 13, 2011. In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be suspended until 30 days after the Court enters a ruling on the dispositive motions, or otherwise by further order of the Court. 7. Interim Status Reports: In accordance with Local Rule 26-3, an Interim Status Report will be filed by the parties with the Court 60 days prior to the discovery cut-off date, and therefore not later than January 13, 2011. 8. Extensions or Modifications of the Discovery Plan and Scheduling Order: In accordance with Local Rule 26-4, any stipulation or motion for modification or extension of this discovery plan and scheduling order must be made no later than 20 days prior to the discovery cut-off date, and therefore not later than February 22, 2011.

12
9555 S. Eastern Ave., Suite 280 Las Vegas, Nevada 89123 [phone] FAX: [phone]

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11
COGBURN LAW OFFICES

Dated: November 29th 2010. Respectfully Submitted By: ______________________________ /s/ Andrew L. Rempfer, Esq. COGBURN LAW OFFICES Andrew L. Rempfer, Esq. Attorneys for Plaintiff _________________________________

IT IS SO ORDERED.

United States Magistrate Judge DATED: ___________________________

12-3-10

12
9555 S. Eastern Ave., Suite 280 Las Vegas, Nevada 89123 [phone] FAX: [phone]

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 3 of 3