Bobadilla et al v. Sorensen et al

Filing 14

ORDER granting 13 Amended Stipulation. IT IS HEREBY ORDERED that the discovery deadlines in the above entitled matter shall be Amended with respect to the Rebuttal Expert deadline extended to 3/30/2015. Signed by Magistrate Judge Carl W. Hoffman on 12/12/2014. (Copies have been distributed pursuant to the NEF - DKJ)

Case 2:14-cv-01233-JAD-CWH Document 13 Filed 12/09/14 Page 1 of 3

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UNITED STATES DISTRICT COURT

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WWW.THARPE-HOWELL.COM

T H A R P E & H O W E L L, LLP

ATTORNEYS AT LAW
6897 WEST CHARLESTON BOULEVARD, LAS VEGAS, NV 89117
PHONE: [phone] | FAX: [phone]

1 Brad R. Kohler II, Esq.
Nevada Bar No.: 7408
2 Brooke A. Bohlke, Esq.
Nevada Bar No.: 9374
3 Lora A. Stanley, Esq.
Nevada Bar No.: 10448
4 THARPE & HOWELL, LLP
6897 West Charleston Boulevard
5 Las Vegas, Nevada 89117
(702) 562–3301
6 Fax: [phone]
[e-mail]
7 [e-mail]
[e-mail]
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Attorneys for Defendants,
9 Robert Sorensen and L&N Transport, Inc.

DISTRICT OF NEVADA

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* * *

13 VENUS M. BOBADILLA, individually and as
Guardian ad Litem of ZAVANNAH
14 BOBADILLA, a minor, and FLOREMLISA N.
MONTANO,
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Plaintiffs,
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vs.
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ROBERT W. SORENSEN; L&N
18 TRANSPORT, INC.; DOES 1 through 5, and
ROE BUSINESS ENTITIES 1 through 5,
19 inclusive,
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Case No.: 2:14-cv-1233-JAD-CWH
AMENDED
STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES
(First Request)

Defendants.
26238

IT IS HEREBY STIPULATED by and between Plaintiffs, VENUS M. BOBADILLA,

23 individually and as Guardian ad Litem of ZAVANNAH BOBADILLA, a minor, and
24 FLOREMLISA N. MONTANO, and Defendants, ROBERT W. SORENSEN and L&N
25 TRANSORT, Inc., by and through their respective counsel of record, pursuant to EDCR 2.35
26 that due to a typographical error in the Stipulation and Order to Extend Discovery Deadlines
27 (First Request) [12], the date for the Rebuttal Expert Designations should be amended as follows
28 (amended information appears in bold):

Case 2:14-cv-01233-JAD-CWH Document 13 Filed 12/09/14 Page 2 of 3

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1. Summary of Discovery Completed
All parties have provided initial witness lists and documents pursuant to N.R.C.P. 16.1 as

3 well as supplements thereto. Defendants have served written discovery requests to all Plaintiffs,
4 all of whom have served responses thereto. Depositions of eyewitness, Michael Penosa, and
5 Plaintiff, Venus Bobadilla, individually and as Guardian ad Litem for Zavannah Bobadilla, have
6 been taken.
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2. Discovery Remaining

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Depositions of Plaintiff, Floremliza N. Montano, Plaintiffs’ treating physicians and the

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3. Reason Why Discovery Was Not Completed

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WWW.THARPE-HOWELL.COM

T H A R P E & H O W E L L, LLP

ATTORNEYS AT LAW
6897 WEST CHARLESTON BOULEVARD, LAS VEGAS, NV 89117
PHONE: [phone] | FAX: [phone]

9 parties’ expert witnesses (once they are disclosed) need to be taken.

At the time of the filing of this Stipulation, no discovery deadlines have passed. However, the

12 parties have scheduled a mediation with Honorable Gene Porter [Retired] for January 5, 2015
13 and wish to extend discovery deadlines by 60 days to allow time for settlement negotiations to
14 take place. The 60-day extension will allow the parties to avoid incurring the additional expense
15 of expert witnesses designations prior to the mediation in the event that settlement is reached.
16 Additionally, the parties believe that expert expenses will render settlement at the January 5,
17 2015 mediation more difficult to reach.
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4. A Proposed Schedule for Completing Discovery
Accordingly, the parties respectfully request that this Court enter an order setting the

20 following discovery plan and scheduling order dates:
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Event

Former Deadline

New Deadline

Discovery cutoff

February 24, 2015

April 24, 2015

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Motions to amend pleadings and November 6, 2014
add parties

January 6, 2015

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Expert Designations

December 26, 2014

February 26, 2015

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Rebuttal expert designations

January 26, 2015

March 30, 2015

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Interim status report

December 26, 2014

February 26, 2015

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Case 2:14-cv-01233-JAD-CWH Document 13 Filed 12/09/14 Page 3 of 3

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Dispositive motions

Dated this 2nd day of December, 2014.

BENSON & BINGHAM

THARPE & HOWELL, LLP

/s/ Israel P. Whitbeck
Joseph L. Benson, II, Esq.
Nevada Bar No.: 7267
Israel P. Whitbeck, Esq.
Nevada Bar No.: 12519
11441 Allerton Park, Dr., Suite 100
Las Vegas, Nevada 89135
Attorneys for Plaintiffs

/s/ Lora A. Stanley
Brad R. Kohler II, Esq.
Nevada Bar No.: 7408
Brooke A. Bohlke, Esq.
Nevada Bar No.: 9374
Lora A. Stanley, Esq.
Nevada Bar No.: 10448
6897 West Charleston Boulevard
Las Vegas, Nevada 89117
Attorneys for Defendants

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WWW.THARPE-HOWELL.COM

ATTORNEYS AT LAW
6897 WEST CHARLESTON BOULEVARD, LAS VEGAS, NV 89117
PHONE: [phone] | FAX: [phone]

T H A R P E & H O W E L L, LLP

May 26, 2015

Dated this 2nd day of December, 2014.

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March 26, 2015

ORDER
Based upon the foregoing Stipulation of the parties hereto, and good cause appearing

12 therefore,
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IT IS HEREBY ORDERED that the discovery deadlines in the above entitled matter shall

14 be Amended with respect to the Rebuttal Expert extended as set forth above.
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IT IS SO ORDERED.
DATED this 12th day of _______________, 2014.
____ day December, 2014.

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United States Magistrate Judge

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