Djordjevic-Mikic et al v. Privilege Underwriters Reciprocal Exchange

Filing 23

ORDER granting 22 Stipulation; Discovery due by 9/14/2018. Motions due by 10/15/2018. Proposed Joint Pretrial Order due by 11/14/2018. Signed by Magistrate Judge Carl W. Hoffman on 5/1/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02667-JCM-CWH Document 22 Filed 04/27/18 Page 1 of 5

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FARHAN R. NAQVI
Nevada Bar No. 8589
ELIZABETH E. COLEMAN
Nevada Bar No. 12350
NAQVI INJURY LAW
9500 W Flamingo Road, Suite 104
Las Vegas, Nevada 89147
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SLOBODANKA DJORDJEVIC-MIKIC,
individually,

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STIPULATION AND ORDER TO
EXTEND DISCOVERY

Plaintiff,

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Case No.: 2:17-cv-02667-JCM-CWH

vs.

(FIRST REQUEST)

PRIVILEGE UNDERWRITERS
RECIPROCAL EXCHANGE a/k/a PURE;
DOES I through X and ROE
CORPORATIONS I through X, inclusive,
Defendants.

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Plaintiff, SLOBODANKA DJORDJEVIC-MIKIC, by and through her counsel of record,

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NAQVI INJURY LAW, and Defendant PRIVILEGE UNDERWRITES RECIPROCAL

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EXCHANGE a/k/a PURE, by and through its counsel of record, TYSON & MENDES LLP,

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submit this STIPULATION AND ORDER TO EXTEND DISCOVERY (FIRST REQUEST)

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pursuant Rules 6(b) and 26(f) of the Federal Rules of Civil Procedure and Local Rules 6-1 and

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26-4 for the Court’s consideration:

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Case 2:17-cv-02667-JCM-CWH Document 22 Filed 04/27/18 Page 2 of 5

I.

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DISCOVERY COMPLETED TO DATE

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1.

A 26(f) Conference was held and a Discovery Plan and Scheduling Order was filed.

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Plaintiff has made initial disclosures as well as a supplement thereto.

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Defendant has made initial disclosures.

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4.

Plaintiff has propounded a first set of request for production upon Defendant.

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5.

Defendant has responded to Plaintiff’s first set of request for production.

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6.

Plaintiff has propounded a first set of interrogatories upon Defendant.

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Defendant has responded to Plaintiff’s first set of interrogatories.

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Plaintiff has propounded a first set of request for admissions upon Defendant.

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Defendant has responded to Plaintiff’s first set of request for admissions.

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10.

Defendant has propounded a first set of request for production upon Plaintiff.

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Plaintiff has responded to Defendant’s first set of request for production.

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II.

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DISCOVERY TO BE COMPLETED

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1.

Expert retention and disclosures;

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2.

The deposition of the 30(b)(6) designee for Defendant;

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Depositions of various witnesses including, but not limited to:

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a. Plaintiff;

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b. Plaintiff’s treating physicians;

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c. Experts;

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d. Other witnesses;

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4.

Production of additional records related to Plaintiff’s medical treatment;

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Case 2:17-cv-02667-JCM-CWH Document 22 Filed 04/27/18 Page 3 of 5

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Additional written discovery; and

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Any other discovery which may be determined relevant and necessary.

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III.
WHY DISCOVERY CANNOT BE COMPLETED IN THE TIME PROVIDED BY THE
SCHEDULING ORDER

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Good cause exists in this case to grant a discovery extension. Plaintiff – who asserts a
brain and other injuries in this case – has recently produced diagnostic brain scans to Defendant

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for expert review. As such, additional time is needed to thoroughly evaluate the scans, as well

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as all other relevant medical records, before expert disclosures are made. Likewise, Defendant

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has recently disclosed hundreds of pages of records, including the claims file, which are

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necessary for evaluation prior to expert disclosure and retention.

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In addition to the foregoing, an extension of the discovery deadlines is necessary as the

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parties are working together to arrange depositions. Specifically, the deposition of Defendant’s

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30(b)(6) designee, which the parties are currently working to arrange, must be taken prior to the

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initial expert disclosure so that the experts can review the transcript from said deposition prior to

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completing their reports. Therefore, the parties request that the discovery deadlines be extended

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as indicated below:
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Case 2:17-cv-02667-JCM-CWH Document 22 Filed 04/27/18 Page 4 of 5

IV.

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PROPOSED SCHEDULE FOR COMPLETING REMAINING DISCOVERY

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DISCOVERY
Motion to Amend
Pleadings:

Closed

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Initial Expert Disclosures

July 16, 2018

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Rebuttal Expert
Disclosures:

August 15, 2018

Close of Discovery

September 14, 2018

Dispositive Motions:

October 15, 2018

Interim Status Report

July 16, 2018

Joint Pre-Trial Order:

November 14, 2018

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PROPOSED DEADLINE

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Dated this _27th_day of April, 2018.

Dated this _27th_day of April, 2018.

NAQVI INJURY LAW

TYSON & MENDES LLP

_/s/ Elizabeth Coleman________________
FARHAN R. NAQVI
Nevada Bar No. 8589
ELIZABETH E. COLEMAN
Nevada Bar No. 12350
9500 W Flamingo Road, Suite 104
Las Vegas, Nevada 89147
Attorneys for Plaintiff

_/s/ Carrie McCrea Hanlon____________
THOMAS E. MCGRATH
Nevada Bar No. 7086
CARRIE MCCREA HANLON
Nevada bar No. 3902
3960 Howard Hughes Pkwy., Suite 600
Las Vegas, Nevada 89169
Attorneys for Defendant

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May 1, 2018

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Case 2:17-cv-02667-JCM-CWH Document 22 Filed 04/27/18 Page 5 of 5

ORDER

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IT IS SO ORDERED this _______ day of __________________, 2018.

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______________________________________
United States District Court Judge

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Respectfully Submitted By:

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NAQVI INJURY LAW

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_/s/ Elizabeth Coleman________
FARHAN R. NAQVI
Nevada Bar No. 8589
ELIZABETH E. COLEMAN
Nevada Bar No. 12350
9500 W Flamingo Road, Suite 104
Las Vegas, Nevada 89147
Attorneys for Plaintiff

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