Martinez v. University Medical Center

Filing 16

ORDER ON STIPULATION Granting 15 STIPULATION to Extend Deadlines. Discovery due by 12/2/2013. Motions due by 1/2/2014. Proposed Joint Pretrial Order due by 2/1/2014. Signed by Magistrate Judge Cam Ferenbach on 8/22/13. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-00003-APG-VCF Document 15 Filed 08/13/13 Page 1 of 4

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Michael P. Balaban, State Bar No. 9370
LAW OFFICES OF MICHAEL P. BALABAN
10726 Del Rudini Street
Las Vegas, NV 89141
[phone]
Fax: [phone]
Attorney for Plaintiff
MARTIN MARTINEZ

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Jeffrey I. Pitegoff, State Bar No. 5458
PITEGOFF LAW OFFICE
415 South Sixth Street, Suite 300
Las Vegas, NV 89101
[phone]
Fax: [phone]
Attorney for Defendant
UMC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARTIN MARTINEZ,

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Plaintiff,
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vs.
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CLARK COUNTY, a political subdivision, and )
municipality including its department,
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UNIVERSITY MEDICAL CENTER,
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Defendants.
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CASE NO. 2:13-cv-00003-APG-VCF
STIPULATION AND ORDER TO AMEND
DISCOVERY PLAN AND SCHEDULING
ORDER
[FIRST REQUEST]

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Plaintiff, MARTIN MARTINEZ (hereinafter "Plaintiff" or “Martinez”) and Defendant,

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CLARK COUNTY, a political subdivision, and municipality including its department,

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UNIVERSITY MEDICAL CENTER (hereinafter "Defendant" or “UMC”), by and through their

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Case 2:13-cv-00003-APG-VCF Document 15 Filed 08/13/13 Page 2 of 4

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undersigned counsel, hereby agree and stipulate to amend the current Discovery Plan and

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Scheduling Order (Dkt #11), by extending the current discovery cut-off date of September 2, 2013

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and related dates 90 days.

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1.

Statement specifying the discovery completed to date.

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Plaintiff:

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Initial disclosures

May 3, 2013

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Plaintiff’s First Set of Requests for Production

May 25, 2013

Plaintiff’s First Set of Interrogatories

May 25, 2013

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Responses to Defendant’s Interrogatories

Currently due September 2, 2013

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Responses to Defendant's Requests for Production

Currently due September 2, 2013

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Defendant:

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Initial Disclosures

May 6, 2013

First Supplement Initial Disclosures

June 5, 2013

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Responses to Plaintiff’s First Set of Interrogatories

July 22, 2013

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Responses to Plaintiff’s First Set of Requests for
Production

July 23, 2013

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Defendant's Interrogatories (Set One) to Plaintiff

August 2, 2013

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Defendant's Requests for Production of Documents
and other Tangible Things (Set One) to Plaintiff

August 2, 2013

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2.

A specific description of the discovery that remains to be completed.
Plaintiff currently desires to depose Karen Edwards, James Mumford, Anthony Tyler,

Teresa Scupi, Cheryl Zimmer, Vicki Wolms, Firooz Mashhood, M.D. and G. Michael Elkanich,
M.D. Defendant currently desires to depose Plaintiff. Both parties are in the process of

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scheduling these depositions.

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Case 2:13-cv-00003-APG-VCF Document 15 Filed 08/13/13 Page 3 of 4

In addition both parties might propound additional written discovery.

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The reasons why the discovery remaining was not completed within the time limits set

by the scheduling order.

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1.

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judgment, in addition to his workload in other cases; and

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Counsel for Plaintiff has recently prepared two oppositions to motions for summary

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Defendant's counsel is currently involved in a complex matter involving three

separate cases consolidated for discovery purposes. In addition, Defendant's counsel has been
involved in three labor arbitration matters which have consumed more time than anticipated.

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4.

A proposed schedule for completing all remaining discovery.

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1.

Last day to conduct discovery: December 2, 2013.

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2.

Last day to file dispositive motions: January 2, 2013.

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3.

Last day to file Joint Pretrial Order: February 1, 2013. In the event dispositive

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2014
2014

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motion(s) are filed, the date for filing the Joint Pretrial Order shall be suspended until 30 days

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after the Court enters a ruling on the dispositive motions, or otherwise by further order of the

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Court.

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This is the parties’ first request for an extension of the discovery deadline and is being
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done 20 days before the current discovery cut-off.

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For good cause shown, the parties request that this stipulation and order be granted.
Respectfully submitted,
DATED: 08/13/2013

LAW OFFICES OF MICHAEL P. BALABAN

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BY:

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/s/ Michael P. Balaban
Michael P. Balaban
LAW OFFICES OF MICHAEL P. BALABAN
10726 Del Rudini Street
Las Vegas, NV 89141

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Case 2:13-cv-00003-APG-VCF Document 15 Filed 08/13/13 Page 4 of 4

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DATED: 08/13/2013

PITEGOFF LAW OFFICE

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BY:

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/s/ Jeffery Pitegoff
Jeffery Pitegoff
PITEGOFF LAW OFFICE
415 South Sixth Street, Suite 300
Las Vegas, NV 89101

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ORDER

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IT IS SO ORDERED.
22nd
Dated this
day of August

, 2013
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Honorable Cam Ferenbach
United States Magistrate Judge

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