Weidner v. State of Nevada et al

Filing 19

ORDER Granting, as amended, 18 Joint Motion to Extend Time re Discovery. Discovery due by 8/25/2017. Motions due by 9/25/2017. Proposed Joint Pretrial Order due by 10/25/2017. Signed by Magistrate Judge Nancy J. Koppe on 3/2/17. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:16-cv-02716-RFB-NJK Document 13 Filed 03/01/17 Page 1 of 3

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Sean K. Claggett, Esq.
Nevada Bar No. 008407
Jennifer Morales, Esq.
Nevada Bar No. 008829
Matthew S. Granda, Esq.
Nevada Bar No. 012753
CLAGGETT & SYKES LAW FIRM
4101 Meadows Lane, Suite 100
Las Vegas, Nevada 89107
[phone] – Telephone
[phone] – Facsimile
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff, Robin Novotny
UNITED STATES DISTRCT COURT

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DISTRICT OF NEVADA

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4101 Meaows Lane, Suite 100
Las Vegas, Nevada 89107
702-655-2346 • Fax [phone]

CLAGGETT & SYKES LAW FIRM

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ROBIN NOVOTNY, an Individual,

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CASE NO.: 2:16-cv-02716-RFB-NJK

Plaintiff,

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v.

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OUTBACK STEAKHOUSE OF FLORIDA,
LLC d/b/a OUTBACK STEAKHOUSE, a
Florida Limited Liability Company; DOE
EMPLOYEE I, an Individual; DOES I-X; and
ROE BUSINESS ENTITIES XI-XX, inclusive,

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STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES
(First Request)

Defendants.
_______________________________________

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Plaintiff, ROBIN NOVOTNY, by and through her counsel of record, CLAGGETT & SYKES

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LAW FIRM; Defendant, OUTBACK STEAKHOUSE OF FLORIDA, LLC d/b/a OUTBACK

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STEAKHOUSE, by and through its counsel of record WILSON ELSER MOSKOWITZ EDELMAN

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& DICKER, LLP, hereby stipulate as follows:

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1.

Discovery completed: to date, the parties have participated in a Fed. R. Civ. P. 26(f)

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Conference, made initial disclosures of documents and witnesses and have propounded and responded

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to written discovery.

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2.

Discovery remaining to be completed: The parties need to disclose initial experts,

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rebuttal experts, conduct the depositions of Plaintiff and Defendant’s 30(b)(6) witnesses, and any

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additional witnesses as needed.
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Case 2:16-cv-02716-RFB-NJK Document 13 Filed 03/01/17 Page 2 of 3

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3.

previously set by the Court: Plaintiff recently received discovery responses from the Defendant that
identified witnesses and documents that were not previously disclosed. Plaintiff believes that some
of these witnesses needs to be deposed prior to the disclosure of expert witnesses. Defendant disagrees
with this assertion.

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Plaintiff also plans on deposing Defendant’s 30(b)(6) witnesses and noticing a site inspection.
Plaintiff’s counsel is 35 weeks pregnant and scheduled to have a baby in March 2017 and will need
time to take the necessary depositions. Outback is capable of meeting the current deadlines but is
agreeable to the accommodation based on Plaintiff’s counsel’s due date.

4101 Meaows Lane, Suite 100
Las Vegas, Nevada 89107
702-655-2346 • Fax [phone]

CLAGGETT & SYKES LAW FIRM

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Description of why remaining discovery has not been completed within the time limits

4.

Proposed schedule for completing all remaining discovery: Based on the foregoing, the

parties respectfully request that the Court grant their joint request to extend the discovery deadlines,
as follows:
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Case 2:16-cv-02716-RFB-NJK Document 13 Filed 03/01/17 Page 3 of 3

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Current Dates
Last day to complete discovery
Last day to make initial expert disclosures
Last day to make rebuttal expert disclosures

May 30, 2017
March 31, 2017
May 1, 2017

Proposed Dates
July 31, 2017
May 31, 2017
June 30, 2017

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Pursuant to Local Rule 26-4, this Stipulation is being submitted to the Court more than

twenty-one (21) days before the first deadline being extended.
IT IS SO STIPULATED.
Dated: March 1, 2017

Dated: March 1, 2017

CLAGGETT & SYKES LAW FIRM

WILSON ELSER MOSKOWITZ EDELMAN
& DICKER, LLP

/s/ Jennifer Morales
___________________________________
Sean K. Claggett, Esq.
Nevada Bar No. 008407
Jennifer Morales, Esq.
Nevada Bar No. 008829
Matthew S. Granda, Esq.
Nevada Bar No. 012753
4101 Meadows Lane, Suite 100
Las Vegas, Nevada 89107
Attorneys for Plaintiff

/s/ Michael P. Lowry
_____________________________________
Michael P. Lowry, Esq.
300 S. 4th St., 11th Floor
Las Vegas, Nevada 89101
Attorneys for Defendant, OUTBACK
STEAKHOUSE OF FLORIDA d/b/a
OUTBACK STEAKHOUSE

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4101 Meaows Lane, Suite 100
Las Vegas, Nevada 89107
702-655-2346 • Fax [phone]

CLAGGETT & SYKES LAW FIRM

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6.

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ORDER

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IT IS SO ORDERED.
2nd day _______________, 2017.
DATED this ____ day ofof March

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______________________________________
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE

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