Calarco v. Sunrise Hospital & Medical Center

Filing 24

ORDER granting 23 Stipulation; Discovery due by 4/30/2018. Motions due by 5/29/2018. Proposed Joint Pretrial Order due by 6/19/2018. Signed by Magistrate Judge George Foley, Jr on 2/8/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-01682-APG-GWF Document 23 Filed 02/07/18 Page 1 of 4

1 BRUCE C. YOUNG, ESQ., NV Bar # 5560
SCOTT H. BARBAG, ESQ., NV Bar # 14164
2 LEWIS BRISBOIS BISGAARD & SMITH LLP
6385 S. Rainbow Boulevard, Suite 600
3 Las Vegas, Nevada 89118
TEL: [phone]
4 FAX: [phone]
[e-mail]
5 [e-mail]
Attorneys for Sunrise Hospital and
6 Medical Center, LLC
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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11 NANCY CALARCO,
Plaintiff,

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vs.

14 SUNRISE HOSPITAL AND MEDICAL
CENTER, LLC,
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Defendant.
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CASE NO. 2:17-cv-01682-APG-GWF
STIPULATION AND ORDER TO EXTEND
DISCOVERY AND OTHER DEADLINES
(FIRST REQUEST)

Pursuant to LR 26-4, the parties, by and through their respective counsel of record,

18 hereby stipulate and request that this Court extend discovery in the above-captioned case sixty
19 (60) days, up to and including April 30, 2018. In addition, the parties request that the
20 dispositive motions and pretrial order deadlines be extended in accordance with the discovery
21 extension as outlined herein. In support of this Stipulation and Request, the parties state as
22 follows:
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1.

On June 16, 2017, Plaintiff filed her Complaint (ECF No. 1).

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2.

On September 1, 2017, Defendant filed its Answer to the Complaint (ECF No. 13).

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3.

On October 10, 2017, the parties prepared and filed their Proposed Discovery Plan
The Court approved and entered the

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LEWIS

and Scheduling Order (ECF No.16).

Discovery Plan and Scheduling Order on October 11, 2017 (ECF No. 17).

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BRISBOIS

BISGAARD
& SIVITH UP
ATTORNEYS AT LAW

4824-0534-8700.1

Case 2:17-cv-01682-APG-GWF Document 23 Filed 02/07/18 Page 2 of 4

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4.

Defendant produced served its initial disclosures pursuant to Rule 26(a)(1) on

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November 6, 2017. Plaintiff served her initial disclosures pursuant to Rule 26(a)(1)

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on November 16, 2017.

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5.

Defendant served written discovery requests (Interrogatories and Requests for

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Production of Documents) to Plaintiff on November 14, 2017. Plaintiff responded

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to the Interrogatories on December 29, 2017 and to the Requests for Production on

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January 2, 2018.

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6.

2017.

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The parties participated in an Early Neutral Evaluation ("ENE") on November 16,

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Plaintiff provided First Supplemental Responses to Defendant's Interrogatories,

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First Supplemental Responses to Defendant's Requests for Production and First

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Supplemental Disclosures on January 16, 2018.

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8.

Production and Second Supplemental Disclosures on January 18, 2018.

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Plaintiff provided Second Supplemental Responses to Defendant's Requests for

9.

Plaintiff propounded Interrogatories and Requests for Production of Documents on
Defendant is in the process of obtaining

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Defendant on January 18, 2018.

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information to respond to these written discovery requests.

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10.

Plaintiff's deposition was scheduled to be taken on several occasions but has been

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continued due to conflicts with Plaintiff's work schedule and most recently as a

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result of an illness in the family of a Sunrise representative assisting in the defense

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of this matter.
DISCOVERY REMAINING

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1.

Defendant intend to provide responses to Plaintiff's written discovery on February

24 20, 2018, unless additional time is required.
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2.

Defendant intends to take Plaintiff's deposition at the end of February or during the

26 first week of March, 2018.
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LEWIS

3.

The parties will take the depositions of any and all other necessary witnesses as

28 determined through discovery.

BRISBOIS
BISGAARD
& SVII1H LIP
ATTORNEYS AT LAW

4824-0534-8700.1

2

Case 2:17-cv-01682-APG-GWF Document 23 Filed 02/07/18 Page 3 of 4

The parties will issue and respond to any necessary additional written discovery.

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4.

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This Request for an extension of time is not sought for any improper purpose or other

3 purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient
4 time to finish necessary discovery.
WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED

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As indicated above, Plaintiff's deposition has been postponed on two occasions, initially as

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7 a result of a conflict with Plaintiff's work schedule and most recently as a result of an illness in the
8 family of a Sunrise representative who is assisting with the defense of this matter. An additional
9 60 days will allow the parties to take depositions and follow up with any necessary written
10 discovery within the time frame of the extension.
In light of these circumstances, the parties require the brief requested extension in order to

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12 complete discovery. The following is a list of the current discovery deadlines and the parties'
13 proposed extended deadlines.
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Scheduled Event

Current Deadline

Proposed Deadline

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Discovery Cut-off

February 28, 2018

April 30, 2018

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Dispositive Motion

March 30, 2018

May 29, 2018

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Pretrial Order

April 30, 2018

June 29, 2018

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This Request for an extension of time is not sought for any improper purpose or other

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LEWIS

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purpose of delay. Rather, it is sought by the parties solely for the purpose of allowing sufficient
time to finish necessary discovery.
II/
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BRISBOIS
BISGAARD
&SMTH LIP
ATTORNEYS AT LAW

4824-0534-8700.1

3

Case 2:17-cv-01682-APG-GWF Document 23 Filed 02/07/18 Page 4 of 4

APPROVED AS TO FORM AND CONTENT.

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DATED this 7th day of February, 2018.

DATED this 7th day of February, 2018.

3 LEWIS BRISBOIS BISGAARD
& SMITH LLP
4

REMPFER MOTT LUNDY, PLLC

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6

10

RUCE
, ES •
5560
Neva
63
1 ow B levard, Suite 600
as
Ne a 89118
To e• 12.893.3383
sim e: 702.893.3789

/s/ Scott E. Lundy
SCOTT E. LUNDY, ESQ.
Nevada Bar No. 14235
10091 Park Run Dr., Suite 200
Las Vegas, NV 89145
Telephone [phone]
Facsimile: [phone]

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Attorneys for Defendant

Attorneys for Plaintiff

By
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ORDER

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UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT/MAGISTRATE JUDGE

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DATED: February 8, 2018

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LEWIS

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BRISBOIS
BISGAARD
&MN W3
ATTORNEYS AT LAW

4824-0534-8700.1

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