Ruhlmann et al v. Rudolfsky et al

Filing 102

ORDER Granting 96 Motion to Modify Scheduling Order. Discovery due by 2/13/2017. Motions due by 3/13/2017. Proposed Joint Pretrial Order due by 4/12/2017. No further extensions will be granted. Signed by Magistrate Judge Nancy J. Koppe on 09/08/2016. (Copies have been distributed pursuant to the NEF - NEV)

Case 2:14-cv-00879-RFB-NJK Document 96-2 Filed 09/01/16 Page 1 of 3

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ELIZABETH J. FOLEY
NEVADA BAR NO.: 1509
MARGARET G. FOLEY
NEVADA BAR NO.: 7703
ELIZABETH J. FOLEY LAWYER, LTD.
601 So. Rancho Drive, Suite A-1
Las Vegas, Nevada 89106
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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ELIZABETH J. FOLEY
LAWYER, LTD.
601 S. Rancho Drive, Suite A-1
Quail Park II
Las Vegas Nevada 89106
Phone: [phone] ! Fax: [phone]

MAX RUHLMANN and ERIC SAMBOLD,

CASE NO.: 2:14-cv-00879-RFB-NJK

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Plaintiffs,
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v.
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GLENN RUDOLFSKY, individually and DBA
HOUSE OF DREAMS KAUAI and HOUSE OF
DREAMS HAWAII; KIM D. RUDOLFSKY,
AKA KIMI DAPOLITO, individually; and DBA
HOUSE OF DREAMS KAUAI and HOUSE OF
DREAMS HAWAII
Defendants.

PROPOSED AMENDED
JOINT DISCOVERY PLAN
AND SCHEDULING ORDER
(Docket No. 96)

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Plaintiffs, MAX RUHLMANN and ERIC SAMBOLD, by and through their undersigned

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counsel, and Defendants, MAX RUDOLFSKY and KIM RUDOLFSKY through their counsel,

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hereby respectfully submit a joint proposed Amended Discovery Plan and Scheduling Order

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pursuant to LR 26-1(b).

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A. The parties conferred by letters, emails and telephone calls multiple times as
required by Fed. R. Civ. P. 26(f). The parties agree to the following Amended Discovery Plan.
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Case 2:14-cv-00879-RFB-NJK Document 96-2 Filed 09/01/16 Page 2 of 3

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B. Discovery Dates:

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1. Discovery Cut-Off Date:

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The parties shall have one hundred eighty (180) days from the date this report is filed in
which to complete discovery. The proposed discovery cut-off date shall be on or before February
13, 2017.

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ELIZABETH J. FOLEY
LAWYER, LTD.
601 S. Rancho Drive, Suite A-1
Quail Park II
Las Vegas Nevada 89106
Phone: [phone] ! Fax: [phone]

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2. Amending the Pleadings and Adding Parties:
The parties agree that the last date for filing motions to amend the pleadings or add
parties shall be no later that ninety (90) days prior to the close of discovery. The proposed date
shall be on or before November 14, 2016.
3. FRCP 26(a)(2) Disclosures (Experts):
The parties agree that the last date for disclosure of expert witnesses shall be sixty (60)
days before the close of discovery. The last date for disclosures shall be on or before December
13, 2016.

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4. Dispositive Motions:
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The parties agree that the last date for filing dispositive motions shall be not later than
thirty (30) days after the discovery cut-off date. The Dispositive motions shall be made on or
before March 13, 2017.

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5. Pretrial Order:

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The parties agree that the Joint Pretrial Order shall be filed within thirty (30) days of the

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date set for filing of dispositive motions. The Order shall be filed on or before April 12, 2017.
6. FRCP 26 (a)(3) Disclosures:

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The parties agree that the disclosures required by FRCP 26(a)(3) and any objections
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thereto shall be included in the pre-trial order on April 12, 2017.
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7. Alternative Dispute Resolution. The parties have discussed the idea of settlement and
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Case 2:14-cv-00879-RFB-NJK Document 96-2 Filed 09/01/16 Page 3 of 3

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are amenable to settlement discussions. Plaintiffs have asked Defendants for documentation of

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rent amounts and a settlement proposal. After discovery of rental income has been provided, a

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settlement conference or mediation should be scheduled.

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Discussions regarding settlement will continue once newly retained counsel for Defendants has had opportunity to more thoroughly review the case file.

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8. Alternative Forms of Case Disposition. The parties have considered alternative forms
of case disposition and do not feel that they would be appropriate for this case.

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9. Electronic Evidence. Should this case proceed to trial, parties will be submitting

ELIZABETH J. FOLEY
LAWYER, LTD.
601 S. Rancho Drive, Suite A-1
Quail Park II
Las Vegas Nevada 89106
Phone: [phone] ! Fax: [phone]

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electronic evidence.
DATED this 10th day of August, 2016.

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By:

Elizabeth J. Foley

By:

ELIZABETH J. FOLEY
Nevada Bar No.: 1509
MARGARET G. FOLEY
Nevada Bar No.: 7703
601 So. Rancho Dr., Suite A-1
Las Vegas, Nevada 89106
Attorney for Plaintiffs

Valerie Del Grosso

VALERIE DEL GROSSO, ESQ.
Nevada Bar No.: 11103
2620 Regatta Drive #102
Las Vegas, Nevada 89128
Attorney for Defendants

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NO FURTHER EXTENSIONS
WILL BE GRANTED.

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IT IS SO ORDERED. LR 26-1(b)(10).

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Dated: September 8, 2016

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_____________________________________
_____________ ________
_ _____
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NANCY KOPPE
NANCY J. KOPPE
C
States M
United States Magistrate Ju
t
tates Magistrate Judge

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