Top Rank Builders, Inc. et al v. Browning et al

Filing 44

ORDER Granting #43 Stipulation to Stay Discovery. IT IS FURTHER ORDERED that the parties must file a joint status report upon completion of the settlement conference or by 6/11/2018 whichever is sooner. Signed by Magistrate Judge Carl W. Hoffman on 3/12/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 1 of 12

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CHRISTINE E. DRAGE, APC
Nevada Bar No. 6624
JOHN T. WENDLAND, ESQ.
Nevada Bar No. 7207
WEIL & DRAGE, APC
2500 Anthem Village Drive
Henderson, NV 89052
[phone] • Fax [phone]
[e-mail]
[e-mail]
Attorneys for Defendant CHARLES ABBOTT
ASSOCIATES, INC.

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA

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TOP RANK BUILDERS, INC., a Nevada
Corporation; and EFRAIN RENE MORALES
MORENO, individually; and as sole officer and
shareholder of TOP RANK BUILDERS, INC.,

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Plaintiffs,

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v.

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CHARLES ABBOTT ASSOCIATES, INC., a
California Corporation; WILLIAM B.
BROWNING, an individual; AMERICAN
WIND & SOLAR, INC., a Nevada Corporation;
SUNDANCE BUILDERS, LLC, a Nevada
Limited Liability Company; THOMAS R.
FRANK, an individual; COUNTY OF NYE, a
political subdivision of the State of Nevada;
DOES I through X, inclusive; and ROE
ENTITIES XI through XX, inclusive,

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Case No.: 2:16-cv-02903-APG-CWH

STIPULATION AND ORDER TO STAY
ACTION TO ALLOW PARTIES TO
ATTEND MEDIATION AND TO EXTEND
THE DISCOVERY CUT OFF DATE AND
DISPOSITIVE MOTION DEADLINE TO
ALLOW FOR THE COMPLETION OF
ALL PENDING DISCOVERY IF
MEDIATION IS NOT SUCCESSFUL
(Second Request)

Defendants.

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Pursuant to LR 6-2 and 26-4 the Parties, through their respective counsel of record, hereby

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agree and stipulate and request this Court to issue a stay in the pending discovery to allow the

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Parties to participate in mediation or a settlement conference. The Parties further request that the

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current discovery cut-off date be extended to expire thirty (30) days after conclusion of mediation

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or the settlement conference and the dispositive motion deadline be extended to expire at sixty 60)

WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 1 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 2 of 12

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days after the conclusion of mediation or settlement conference. In support of this Stipulation and

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Request, the Parties state as follows:
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A.

DISCOVERY COMPLETED TO DATE
i.

Production of Witnesses and Documents:

1.

Plaintiffs Top Rank Builders, Inc. (“TRB”) and Efrain Rene Morales Moreno

(“Morales”) (collectively, the “Plaintiffs”) produced their Initial List of Witnesses and Documents.
2.

Plaintiffs produced their First Supplemental List of Witnesses and Documents.

3.

Plaintiffs produced their Second Supplemental List of Witnesses and Documents.

4.

Defendant Nye County (“Nye”) produced its Initial List of Witnesses and

Documents.
5.

Defendant Nye produced its First Supplement to List of Witnesses and Documents.

6.

Defendant Nye produced its Second Supplement to List of Witnesses and

Documents.
7.

Defendant Charles Abbott Associates, Inc. (“CAA”) produced its Initial List of

Witnesses and Documents.
8.

Defendant CAA produced its First Supplement to List of Witnesses and

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Documents.
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9.
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Defendant CAA produced its Second Supplement to List of Witnesses and

Documents.
10.

Defendant CAA produced its Third Supplement to List of Witnesses and

Documents.
11.

Defendant CAA produced its Fourth Supplement to its List of Witnesses and

Documents.
12.

Defendant William B. Browning (“Browning”) produced his Initial List of

Witnesses and Documents.
13.

Defendant American Wind & Solar, Inc. (“AWS”) produced its Initial List of

Witnesses and Documents.

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 2 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 3 of 12

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ii.

Written Discovery and Responses:

14.

Plaintiff TRB issued its First Set of Interrogatories to Defendant CAA.

15.

Plaintiff TRB issued his First Set of Interrogatories to Defendant Nye.

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Plaintiff TRB issued its First Set of Interrogatories to Defendant AWS.

17.

Plaintiff TRB issued its First Set of Interrogatories to Defendant Browning.

18.

Plaintiff TRB issued its First Set of Request for Production of Documents to

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Defendant CAA.
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19.
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Plaintiff TRB issued its Second Set of Request for Production of Documents to

Defendant CAA.
20.

Plaintiff TRB issued its First Set of Request for Production of Documents to

Defendant Nye.
21.

Plaintiff TRB issued its First Set of Request for Production of Documents to

Defendant Browning.
22.

Plaintiff TRB issued its First Set of Request for Production of Documents to

Defendant AWS.
23.

Plaintiff Morales issued his First Set of Interrogatories to Defendant CAA.

24.

Plaintiff Morales issued his First Set of Interrogatories to Defendant Nye.

25.

Plaintiff Morales issued his First Set of Interrogatories to Defendant Browning.

26.

Plaintiff Morales issues his First Set of Request for Production of Documents to

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Defendant CAA.
27.

Plaintiff Morales issues his First Set of Request for Production of Documents to

Defendant Nye.
28.

Plaintiff Morales issues his First Set of Request for Production of Documents to

Defendant Browning.
29.

Plaintiff Morales issues his First Set of Request for Admissions to Defendant

Browning.
30.

Plaintiff Morales issues his First Set of Request for Admissions to Defendant Nye.

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 3 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 4 of 12

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31.

Defendant CAA issued its First Set of Interrogatories to Plaintiff TRB.

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Defendant CAA issued its First Set of Interrogatories to Plaintiff Morales.

33.

Defendant CAA issued its First Set of Interrogatories to Defendant Nye.

34.

Defendant CAA issued its First Set of Request for Production of Documents to

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Plaintiff TRB.

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35.

Defendant CAA issued its Second Set of Request for Production of Documents to

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Plaintiff TRB.
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Plaintiff TRB.

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37.

Defendant CAA issued its First Set of Request for Admissions to Defendant AWS.

39.

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Defendant CAA Issued its First Set of Request for Admissions to Defendant Nye.

38.

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Defendant CAA issued its Third Set of Request for Production of Documents to

Defendant CAA issued its First Set of Request for Admissions to Defendant

Browning.

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40.

Defendant Nye issued its First Set of Interrogatories to Plaintiff Morales.

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Defendant Nye issued its First Set of Interrogatories to Plaintiff TRB.

41.

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Defendant Nye issued its First Set of Request for Production of Documents to

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Plaintiff TRB.
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43.
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Plaintiff Morales.

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44.

47.

Defendant Browning issued his First Set of Request for Production of Documents

to Plaintiff Morales.

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Defendant Browning issued his First Set of Request for Production of Documents

to Plaintiff TRB.

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Defendant Browning issued his First Set of Interrogatories to Plaintiff Morales.

46.

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Defendant Browning issued his First Set of Interrogatories to Plaintiff TRB.

45.

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Defendant Nye issued its First Set of Request for Production of Documents to

48.

Defendant Browning issued his First Set of Request for Admissions to Plaintiff

TRB.

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 4 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 5 of 12

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49.

Defendant Browning issued his First Set of Request for Admissions to Plaintiff

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Morales.
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to Defendant CAA.

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Defendant CAA issued its responses to Plaintiff TRB’s First Set of Interrogatories

51.

Defendant Nye issued its responses to Plaintiff TRB’s First Set of Interrogatories to

Defendant Nye.

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52.

Defendant AWS issued its responses to Plaintiff TRB’s First Set of Interrogatories

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to Defendant AWS.
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53.

Interrogatories to Defendant Browning.
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54.

55.

Defendant CAA issued its responses to Plaintiff TRB’s First Set of Request for

Production of Documents to Defendant CAA.

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Defendant Browning issued its first supplement to answers to Plaintiff TRB’s First

Set of Interrogatories to Defendant Browning.

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Defendant Browning issued its responses to Plaintiff TRB’s First Set of

56.

Defendant CAA issued its responses to Plaintiff TRB’s Second Set of Request for

Production of Documents to Defendant CAA.

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57.

Defendant Nye issued its responses to Plaintiff TRB’s First Set of Request for

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Production of Documents to Defendant Nye.
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for Production of Documents to Defendant Browning.

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59.

60.

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Defendant CAA issued its responses to Plaintiff Morales’ First Set of

Interrogatories to Defendant CAA.

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Defendant AWS issued its responses to Plaintiff TRB’s First Set of Request for

Production of Documents to Defendant AWS.

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Defendant Browning issued his responses to Plaintiff TRB’s First Set of Request

61.

Defendant Nye issued its responses to Plaintiff Morales’ First Set of Interrogatories

to Defendant Nye.
///

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 5 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 6 of 12

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62.

Defendant Browning issued his responses to Plaintiff Morales’ First Set of

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Interrogatories to Defendant Browning.
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4

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First Set of Interrogatories to Defendant Browning.

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Defendant Browning issued his first supplement to answers to Plaintiff Morales’

64.

Defendant CAA issued its responses to Plaintiff Morales’ First Set of Request for

Production of Documents to Defendant CAA.

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65.

Defendant Nye issued its responses to Plaintiff Morales’ First Set of Request for

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Production of Documents to Defendant Nye.
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for Production of Documents to Defendant Browning.
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67.

68.

Defendant Browning issued his supplement to answers to Plaintiff Morales’ First

Set of Request for Admissions.

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Defendant Browning issued his responses to Plaintiff Morales’ First Set of Request

for Admissions to Defendant Browning.

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Defendant Browning issued his responses to Plaintiff Morales’ First Set of Request

69.

Defendant Nye issued its responses to Plaintiff Morales’ First Set of Request for

Admissions to Defendant Nye.

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70.

Plaintiff TRB issued its responses to Defendant CAA’s First Set of Interrogatories

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to Plaintiff TRB.
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Interrogatories to Plaintiff Morales.

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72.

73.

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Plaintiff TRB issued its responses to Defendant CAA’s First Set of Request for

Production of Documents to Plaintiff TRB.

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Defendant Nye issued its responses to Defendant CAA’s First Set of Interrogatories

to Defendant Nye.

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Plaintiff Morales’ issued his responses to Defendant CAA’s First Set of

74.

Plaintiff TRB issued its responses to Defendant CAA’s Second Set of Request for

Production of Documents to Plaintiff TRB.
///

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 6 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 7 of 12

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75.

Plaintiff TRB issued its responses to Defendant CAA’s Third Set of Request for

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Production of Documents to Plaintiff TRB.
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Admissions to Defendant Nye.

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Defendant Nye issued its responses to Defendant CAA’s First Set of Request for

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Defendant AWS issued its responses to Defendant CAA’s First Set of Request for

Admissions to Defendant AWS.

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78.

Defendant Browning issued his responses to Defendant CAA’s First Set of Request

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for Admissions to Defendant Browning.
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Plaintiff TRB.

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81.

Plaintiff TRB issued its responses to Defendant Nye’s First Set of Request for

Production of Documents to Plaintiff TRB.

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Plaintiff Morales issued his responses to Defendant Nye’s First Set of

Interrogatories to Plaintiff Morales.

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Plaintiff TRB issued its responses to Defendant Nye’s First Set of Interrogatories to

82.

Plaintiff Morales’ issued his responses to Defendant Nye’s First Set of Request for

Production of Documents to Plaintiff Morales.

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iii.

Experts:

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Plaintiffs TRB and Morales have produced their initial list of expert witnesses,

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summaries and designations.

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84.

qualifications and reports.

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iv.

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Deposition of Plaintiff Efrain Rene Morales, individually and as 30(b)(6) witness

for Plaintiff TRB.

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Depositions

85.

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Defendants CAA and Browning have produced their rebuttal expert witnesses,

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Custodian of Record Depositions for Green Cross of America, Inc. (non-

appearance), SATI Construction and Nye Farm Tech (non-appearance).
///

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 7 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 8 of 12

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87.

Deposition of Nye County’s 30(b)(6) Witness for Nye County’s licensing and

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Permitting Policies and Procedures and Knowledge as to Projects involving Green Cross of
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America, Inc.

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88.

Deposition of Pamela Webster, Nye County Manager.

90.

Deposition of Peter Gnecco, Green Cross of America, Inc.

91.

Deposition of Gary Carlson, AIA.

92.

Deposition of William Browning.

93.

Deposition of Nye Farm Tech, Ltd.’s 30(b)(6) Witness.

v.

Third Party Subpoenas for Records

94.

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Deposition Faith Simunick, former CAA employee.

89.

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Defendant CAA issued subpoena duces tecum to the State of Nevada Board of

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Contractors.

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95.

Defendant CAA issued its subpoena duces tecum to Nye Farm Tech, Ltd.

98.

Defendant Nye issued its subpoena duces tecum to Green Cross of America, Inc.

99.

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Defendant CAA issued its subpoena duces tecum to SATI Construction.

97.

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Defendant CAA issued its subpoena duces tecum to Green Cross of America, Inc.

96.

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Plaintiff TRB issued its subpoena duces tecum to the State of Nevada Board of

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Contractors.
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B.

DISCOVERY REMAINING-IN PROGRESS
The Parties have the following depositions scheduled for this action:
1. The Deposition of the 30(b)(6) witness for Esmeralda County;
2. The Deposition of Guy Marzola, Green Cross of America, Inc.
3. The Deposition of Kevin Fisher, Green Cross of America, Inc.
4. The Deposition of Sean Wilson, TRB and designated as non-retained expert for

Plaintiffs TRB and Morales.
5. The Deposition of Dan Ames, D&J Electrical.
6. The Deposition of Geraldo Guzman, Ganda Concrete.

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 8 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 9 of 12

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7. The Deposition of L. Darrell Lacy, Nye.

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8. Plaintiffs TRB and Morales’ responses to Defendant Browning’s written discovery due
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one week after resumption of discovery.

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9. Any and all supplements to prior discovery requests (written and/or at deposition)
wherein the responding party represented that they will supplement their response at a future date.

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Based on the amounts of fees and costs incurred by the Parties to date, discussions have

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arisen about staying all remaining discovery and litigation and placing this matter into mediation
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or settlement conference. The fees and costs estimated by the Parties moving forward to complete
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discovery; file dispositive motions, oppositions and replies; appear at hearings and court ordered
conferences; engage in extensive pre-trial litigation; and finally prepare for and attend trial is
estimated to be a significant. Extensive discovery has assisted the Parties in identifying and
eliminating claims, issues, damages and to assess any potential risks to the Parties in the action.
Therefore, the Parties believe the time is ripe and there is universal interest in the Parties to pursue
an avenue to stop the further incursion of fees and costs and to engage in meaningful settlement
discussions concerning the action.

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If mediation or settlement conference is not successful, the Parties request the present

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discovery cut-off date be extended to expire thirty (30) days after the formal termination of
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mediation or settlement conference. The Parties further request that any remaining discovery in
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this action following an unsuccessful mediation or settlement be limited to the discovery pending
at the time the Parties entered into this stipulation. The Parties stipulate that following the
conclusion of an unsuccessful mediation or settlement conference, no additional depositions or
written discovery is allowed other than the items expressly stated herein as pending and needing
completion.

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The Parties also stipulate to file notice of recommencement of discovery to the Court,
confirming the commencement date of the resumption of discovery, if the mediation or settlement
conference is unsuccessful.
///

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 9 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 10 of 12

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C.

REASONS WHY DISCOVERY WAS NOT COMPLETED

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As shown herein, the Parties have expended considerable time, energy and costs litigating
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this action. Many depositions have been taken and extensive written discovery and production of
documents from the Parties and third parties have been acquired. Based on the discovery to date,
there is an opportunity for the Parties to engage in detailed, meaningful settlement discussions in
this action in a good faith effort at resolution. Therefore, the Parties stipulate that the time is ripe

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for settlement discussions that may ultimately resolve this action. The remaining discovery stated
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herein has been previously and timely scheduled in anticipation of completion prior to the current
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discovery cut-off date of March 13, 2018. However, the Parties will incur significant fees and
costs completing the discovery and then proceeding to file dispositive motions. These projected
fees and costs could be directed toward meaningful settlement discussions that may resolve the
action.

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The Parties all represent that this extension is being made in good faith and not to
needlessly delay the proceedings.
D.

PROPOSED SCHEDULE FOR COMPLETION OF DISCOVERY

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Current Deadline

Proposed New Deadline

Close of discovery

March 13, 2018

30 days following the
formal conclusion of
mediation or settlement
conference

Amend Pleadings/Add Parties

N/A

N/A

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Initial Experts

September 14, 2017

N/A

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Rebuttal Experts

February 9, 2018

N/A

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Dispositive Motions

April 17, 2018

60 days following the
formal conclusion of
mediation or settlement
conference

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///

WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 10 of 12

Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 11 of 12

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E.

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CURRENT TRIAL DATE
To the knowledge of the Parties, no trial date has been scheduled in this action.

DATED this 9th day of March, 2018.

DATED this 9th day of March, 2018.

WEIL & DRAGE, APC

THE WRIGHT LAW GROUP, P.C.

/s/ John T. Wendland
____________________________________
CHRISTINE E. DRAGE, ESQ.
Nevada Bar No. 6624
JOHN T. WENDLAND, ESQ.
Nevada Bar No. 7207
2500 Anthem Village Drive
Henderson, Nevada 89052
Attorneys for Defendant,
CHARLES ABBOTT ASSOCIATES, INC.

/s/ John Henry Wright
____________________________________
JOHN HENRY WRIGHT, ESQ.
Nevada Bar No. 6182
PHILIP S. GERSON, ESQ.
Nevada Bar No. 5964
2340 Paseo Del Prado, Suite D-305
Las Vegas, NV 89102
Attorneys for Plaintiffs,
TOP RANK BUILDERS, INC. and EFRAIN
RENE MORALES MORENO

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DATED this 9th day of March, 2018.

DATED this 9th day of March, 2018.

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MARQUIS AURBACH COFFING

WOODBURY LAW

/s/ Craig Anderson
____________________________________
CRAIG ANDERSON, ESQ.
Nevada Bar No. 6882
JONATHAN B. LEE, ESQ.
Nevada Bar No. 13524
10001 Park Run Drive
Las Vegas, Nevada 89145
Attorneys for Defendant,
COUNTY OF NYE

/s/ Rodney S. Woodbury
_____________________________________
RODNEY S. WOODBURY, ESQ.
Nevada Bar No. 7216
50 S. Stephanie Street, Suite 201
Henderson, Nevada 89012
Attorneys for Defendants,
AMERICAN WIND & SOLAR, INC. and
WILLIAM BROWNING

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///

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///

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///

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///

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///

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///

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

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Case 2:16-cv-02903-APG-CWH Document 43 Filed 03/09/18 Page 12 of 12

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DATED this 9th day of March, 2018.

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WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

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/s/ David S. Kahn
_____________________________________
DAVID S. KAHN, ESQ.
Nevada Bar No. 7038
300 S. Fourth Street, 4th Fl.
Las Vegas, Nevada 89101
Attorneys for Defendant
WILLIAM BROWNING

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ORDER
IT IS IT ISORDERED. IT IS FURTHER ORDERED that the parties must file a joint
SO SO ORDERED.
status report upon completion of the settlement conference or by June 11, 2018,
whichever is sooner. day of March, 2018.
DATED this ____
DATED: March 12, 2018

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______________________________________
UNITED STATES MAGISTRATE JUDGE

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CASE NO. 2:16-cv-02903-APG-CWH
Top Rank Builders, Inc. v. Charles Abbott
Associates, Inc.

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WEIL & DRAGE
A T T O R N E Y S A T L A W
A PROFESSIONAL CORPORATION

2500 Anthem Village Drive
Henderson, NV 89052
Phone: [phone]
Fax: [phone]
www.weildrage.com

{01354142;1}

Page 12 of 12