Lige v. Clark County et al

Filing 129

ORDER Granting 128 Stipulation to Extend Time. Proposed Joint Pretrial Order due by 5/7/2018. Signed by Judge Jennifer A. Dorsey on 4/23/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-00603-JAD-PAL Document 128 Filed 04/23/18 Page 1 of 5

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DAN M. WINDER, ESQ.
Nevada State Bar No. 1569
KRISTINA MILETOVIC, ESQ.
Nevada State Bar No. 14089
LAW OFFICE OF DAN M. WINDER, P.C.
3507 W. Charleston Blvd.
Las Vegas, NV 89102
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOHN LIGE, an individual,
Plaintiff,

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Case No: 2:16-cv-00603-JAD-(PAL)

vs.

STIPULATION AND ORDER
TO
EXTEND DEADLINE
TO
FILE JOINT PRETRIAL ORDER
[SECOND REQUEST]

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CLARK COUNTY, a political subdivision of
the State of Nevada; DOES I-V; and ROES
VI-X,

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Defendants.

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Plaintiff John Lige, by and through his attorney of record, Dan M. Winder, Esq. of the

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Law Office of Dan M. Winder, P.C., and Defendant Clark County, by and through its attorney of

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record, Danielle C. Miller, Esq. of Lewis Brisbois Biggaard & Smith, hereby stipulate and agree:

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1. The Joint-Pretrial Order in this matter is to be filed by up to and including Monday,

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Monday, May 7, 2018.
4822-5565-0403.1

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Case 2:16-cv-00603-JAD-PAL Document 128 Filed 04/23/18 Page 2 of 5

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The reasons for this request are the following:

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1. In the last week or so and in the next two weeks, Plaintiff’s counsel has been and will

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be working to meet the at least following inordinate amount of deadlines:

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a. Motion for Reconsideration of Interlocutory Order (granting partial motion for

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summary judgment) dated 3/26/18, Evans v. UMC, due asap, District of

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Nevada, Case No. 2:16-cv-00603-JAD-(PAL);

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b. Plaintiff’s responses to Defendant’s First Set of Interrogatories, Requests for

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Admissions, and Second Set of Requests for Production, Muwwakkil v. CCSD,

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due 4/23/18, Eighth Judicial District Court, Case No. A-17-755222-C;

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c. Retention of expert and coordination of expert report, initial disclosure

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deadline 05/02/18, Muwwakkil v. CCSD, Eighth Judicial District Court, Case

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No. A-17-755222-C;

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d. Coordination of rebuttal expert report, rebuttal disclosure deadline 4/30/18,

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jury trial date 09/10/18, Thorpe v. Mumpower, et. al., Eighth Judicial District

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Court, Case No. A-15-714465-C;

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e. Responses to Defendant Mumpower’s Second Set of Requests for Production

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to Plaintiff Thorpe and Plaintiff Burns, due 05/02/18, jury trial date 09/10/18,

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Thorpe v. Mumpower, et. al., Eighth Judicial District Court, Case No. A-15-

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714465-C;

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f. Preparation of Initial Disclosures, Zuniga v. Miller, due 4/23/18, Eighth
Judicial District Court, Case No. A-17-762692-C;

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g. Reply to Defendant Clark County’s Response to Plaintiff’s Motion for

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Reconsideration (ECF No. 127), Lige v. Clark County, due 04/25/18, District

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of Nevada, Case No. 2:16-cv-00603-JAD-(PAL);

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h. Coordinating performance of Compliance Order for Charter Bus company to

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obtain operating authority, 05/07/18 deadline, Nevada Transportation

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Authority Docket No. 17-03035.

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4822-5565-0403.1

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Case 2:16-cv-00603-JAD-PAL Document 128 Filed 04/23/18 Page 3 of 5

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2. Plaintiff has circulated a draft Joint Pretrial Order. Plaintiff and Defendant’s counsel

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seek the instant extension because they have not yet found a mutually available time

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to personally confer. The parties have scheduled May 3, 2018 at 11 AM for the

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personal conference and will work to have a jointly prepared draft finished prior to

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the May 3, 2018 conference.

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3. Counsel for Defendant has also been working and will be working on the following

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matters, which have and will inhibit the ability to assist in the preparation of the Joint

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Pretrial Order:

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a. Arbitration Brief, Hissung v. GEICO, due 4/27/18, Eighth Judicial District
Court, Case No. A-17-758333-C;

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b. Preparation of Initial Disclosures, Mancao v. Clark County, due 4/30/18;
District of Nevada Case No. 2:18-cv-00047-GMN-GWF;

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c. Stipulated Protective Order, Mancao v. Clark County, due 4/30/18; District of
Nevada Case No. 2:18-cv-00047-GMN-GWF;

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d. Reply in Support of Motion to Stay Proceedings, Schneider v. Innette

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Lewis;GEICO as Intervenor, due 5/3/18, Eighth Judicial District Court, Case

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No. A-16-734700-C;

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e. Discovery Responses, Pradera v. GEICO, due 5/8/18, District of Nevada,
Case No. 2:18-cv-00156-MMD-NJK;

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f. Reply in Support of Motion to Stay Proceedings, due 5/11/18, Zervas v.
USAA, District of Nevada, Case No. 2:18-cv-00051-JAD-GWF.

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4. With the newly proposed May 7, 2018 Joint Pretrial Order deadline, this Honorable

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Court would have approximately 316 days in which to set the case for trial within 3

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years of the March 17, 2016 date of the filing of the complaint in the instant matter.

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5. Due to the complex nature of this case and the time constraints discussed above, the

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parties seek a two week extension in which to file their Joint Pretrial Order.

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4822-5565-0403.1

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Case 2:16-cv-00603-JAD-PAL Document 128 Filed 04/23/18 Page 4 of 5

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6. This stipulation is entered into in good faith and not to cause undue delay.

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DATED this 23rd day of April, 2018.

DATED this 23rd day of April, 2018.

Law Office of Dan M. Winder, P.C.

Lewis Brisbois Bisgaard & Smith LLP

__/s/ _Kristina Miletovic___________ ___
DAN M. WINDER, ESQ.
Nevada State Bar No. 1569
KRISTINA MILETOVIC, ESQ.
Nevada State Bar No. 14089
3507 W. Charleston Blvd.
Las Vegas, NV 89102
Attorneys for Plaintiff

___/s/ _Danielle C. Miller_________ ___
ROBERT W. FREEMAN, ESQ.
Nevada State Bar No. 3062
DANIELLE C. MILLER, ESQ.
Nevada State Bar No. 9127
6385 S. Rainbow Blvd., Suite 600
Las Vegas, Nevada 89118
Attorneys for Defendant Clark County

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ORDER

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IT IS HEREBY ORDERED the Joint-Pretrial Order in this matter is to be filed by up to

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and including Monday, May 7, 2018. The parties are cautioned, however, that an attorney's

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workload will not likely qualify as good cause for further extension of this deadline.

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IT IS SO ORDERED this _____ day of ____________________, 20____.

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_________________________________
___________________
_ _ ___ _ _
_________________________________________
U.S. District Judge Jennifer A. Dorsey
strict Judge Jennifer
ct
ni r
UNITED ct ud
STATES MAGISTRATE JUDGE
Dated: A il 23 2018
April 23,

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4822-5565-0403.1

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