Olson v. Spring Valley Surgery Center, LLC

Filing 21

ORDER Granting 20 Stipulation to Extend Discovery Deadlines. Discovery due by 1/18/2016. Motions due by 2/15/2016. Proposed Joint Pretrial Order due by 3/17/2016. Signed by Magistrate Judge Cam Ferenbach on 10/13/2015. (Copies have been distributed pursuant to the NEF - DC)

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GABROY LAW OFFICES
Christian Gabroy (#8805)
Ivy Hensel (#13502)
The District at Green Valley Ranch
170 South Green Valley Parkway, Suite 280
Henderson, Nevada 89012
Tel
[phone]
Fax [phone]
[e-mail]
ATTORNEY FOR PLAINTIFF

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARLENA OLSON, an individual;

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Case No: 2:15-cv-00080-RFB-VCF

Plaintiff,
vs.

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170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

GABROY LAW OFFICES

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SPRING VALLEY SURGERY CENTER,
LLC., a Nevada limited liability company;
EMPLOYEE(S)/AGENT(S) DOES 1-10;
and ROE CORPORATIONS 11-20,
inclusive,

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[PROPOSED] STIPULATION AND
ORDER TO EXTEND DISCOVERY
DEADLINES
[SECOND REQUEST]

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Defendants.
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Plaintiff, Marlena Olson, by and through her attorneys of record, Christian
Gabroy, Esq. and Ivy Hensel, Esq. of Gabroy Law Offices, and Defendant Spring Valley

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Surgery Center, LLC, by and through its attorneys of record, do hereby stipulate and
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agree that the current discovery cutoff date of November 17, 2015 be continued for a

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period of sixty (60) days up to and including January 18, 2015. This is the second

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request to extend discovery in this matter.

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1. DISCOVERY COMPLETED TO DATE:

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The parties exchanged their initial disclosures required under Fed. R. Civ. P.

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26(a)(1)(A) on March 5, 2015. Defendant supplemented its initial disclosures on April

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17, 2015. Both parties have propounded written discovery that has been answered. In
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addition, the parties have met and conferred regarding discovery responses.

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2. DISCOVERY YET TO BE COMPLETED:

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Plaintiff anticipates that another meet and confer conference will take place. Both

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parties anticipate conducting depositions, including the possible depositions of third-

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party witnesses who are not under the control of any of the parties in this litigation. The

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anticipated depositions have not been completed. Defendant anticipates taking the

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deposition of Plaintiff and her physicians and Defendant will make a determination
thereafter as to the necessity of taking additional percipient and/or witness depositions.

Godwin Maduka, Mary Valarde, Michele Coleman, Allison Roe, Michelle Wray, Lauren

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170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

Plaintiff anticipates taking the deposition of numerous witnesses that may include Dr.

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GABROY LAW OFFICES

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Leventer, Sonia Hooker, Paul Shubert, and the person most knowledgeable of Spring

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Valley Surgery Center, LLC.
3. REASONS WHY REMAINING DISCOVERY HAS NOT YET BEEN

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COMPLETED:
An extension is necessary because the parties will likely engage in additional

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meet and confer conferences regarding written discovery responses and require

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additional time to schedule and conduct depositions. Further, Plaintiff’s counsel’s

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daughter was born and, in addition, Plaintiff’s counsel has recently undergone a surgical

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back procedure. Accordingly, additional time is needed to meet and confer regarding

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discovery responses and to take the depositions noted above prior to the discovery
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cutoff. As such, a sixty (60) day extension is requested.
For these reasons, the parties request that the dates set forth in the Court’s

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Order extending discovery deadlines be extended by sixty (60) days and that the

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scheduling Order be amended as follows:

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Page 2 of 4

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4. REVISED DISCOVERY PLAN:
1. Discovery Cut Off Date.
The close of the discovery period shall be extended sixty days from
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November 17, 2015 to January 18, 2015. (January 16, 2015 falls on
a Saturday.)
2. Amending the Pleadings and Adding Parties.

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The deadline to amend the pleadings and add parties has closed.
3. Interim Status Report.
The deadline to file interim status report shall be extended from

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September 20, 2015 to November 19, 2015.

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170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

GABROY LAW OFFICES

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4. Expert Witness Disclosures.
a. Initial Expert Disclosures.
The deadline to disclose initial expert disclosures shall be extended

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from October 18, 2015 to December 17, 2015.
b. Rebuttal Expert Disclosures.

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The deadline to disclose rebuttal expert disclosures shall be

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extended from October 18, 2015 to December 17, 2015.

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5. Dispositive Motions.
The dispositive motion date shall be extended by sixty days from

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December 17, 2015 to February 15, 2016.
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6. Extensions or Modifications of the Discovery Plan and Scheduling Order.
Under Local Rule 26-4, any request to extend discovery deadlines
must be made 21 days prior to the expiration of the subject deadline.

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Page 3 of 4

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7. Pre-trial Order.

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The deadline to file joint pre-trial order (if no dispositive motions are

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pending before the Court) shall be extended from January 17, 2016

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to March 17, 2016.

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DATED this 12th day of October 2015.

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GABROY LAW OFFICES

MORRIS POLICH & PURDY LLP

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170 S. Green Valley Pkwy., Suite 280
Henderson, Nevada 89012
[phone] FAX: [phone]

GABROY LAW OFFICES

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By: /s/__Christian Gabroy______
Christian Gabroy (Bar No. 8805)
Ivy Hensel (Bar No. 13502)
170 South Green Valley Parkway
Suite 280
Henderson, Nevada 89012
Email: [e-mail]
[e-mail]

By: _/s/ Deanna Forbush___________
Deanna L. Forbush (Bar No. 6646)
Sunethra Muralidhara (Bar No. 13549)
500 South Rancho Drive, Suite 17
Las Vegas, Nevada 89106
Email: [e-mail]
[e-mail]

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ORDER
IT IS SO ORDERED.

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_________________________________
UNITED STATES MAGISTRATE JUDGE

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October 13, 2015
DATE: ___________________________

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