Perez v. Twyoford et al
Filing
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ORDER Granting 24 First Stipulation to Extend Deadlines. Proposed Joint Pretrial Order due by 1/7/2018. Discovery due by 11/6/2018. Motions due by 12/10/2018. Signed by Magistrate Judge Cam Ferenbach on 6/20/2018. (Copies have been distributed pursuant to the NEF - SLD)
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THORPE SHWER, P.C.
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THORPE SHWER, P.C.
William L. Thorpe (Arizona Bar No. 005641), Pro Hac Vice
Tyler J. Grim (Arizona Bar No. 031300), Pro Hac Vice
3200 North Central Avenue, Suite 1560
Phoenix, Arizona 85012-2441
Telephone: (602) 682-6100
Facsimile: (602) 682-6149
Email: docket@thorpeshwer.com
Email: wthorpe@thorpeshwer.com
Email: tgrim@thorpeshwer.com
MESSNER REEVES LLP
Renee Finch (Nevada Bar No. 13118)
8945 W. Russell Road, Suite 300
Las Vegas, Nevada 89148
Telephone: (702) 363-5100
Facsimile: (702) 363-5101
Email: rfinch@messner.com
Attorneys for Defendants
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
TAMILENE TANYA PEREZ,
Plaintiff,
v.
TIMOTHY TWYFORD; J.B. HUNT
TRANSPORT, INC.; DOES I-X,
inclusive, and ROE CORPORATIONS
I-X, inclusive,
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STIPULATION TO EXTEND
SCHEDULED DEADLINES
(FIRST REQUEST)
(Assigned to the Hon. Andrew P. Gordon)
Defendants.
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CASE NO. 2:18-cv-00034-APG-VCF
Pursuant to Local Rules IA 6.1 and 26-4, Plaintiff Tamilene Tanya Perez and
Defendants Timothy Twyford and J.B Hunt Transport, Inc. (collectively the “Defendants,”
and together with Plaintiff, the “Parties”) hereby stipulate and agree to extend the deadlines set
forth in the previously filed Joint Discovery Plan for a period sixty (60) days. This is the first
stipulation to extend any deadline in this proceeding.
I.
Discovery Completed to Date
To date, the Parties each propounded written discovery upon one another. Defendants
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served their responses to Plaintiff’s written discovery on April 16, 2018. Plaintiff served her
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responses to Defendants’ written discovery May 15, 2018. A Rule 35 examination of the
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Plaintiff was also conducted on May 23, 2018.
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II.
Discovery Yet to be Completed
Plaintiff’s deposition is currently scheduled for June 26, 2018. Additionally, the Parties
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are still working to coordinate and schedule the depositions of (1) a corporate designee of JB
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Transport, Inc., (2) many of Plaintiff’s medical providers, and (3) Plaintiff’s lay witnesses. As
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detailed below, the Parties have encountered numerous complications in scheduling the
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depositions of the medical providers. The Parties agree that additional discovery is necessary
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to clarify certain categories of damages claimed by Plaintiff. The Parties have also not
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THORPE SHWER, P.C.
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exchanged expert reports or conducted any expert discovery to date. The Parties also will
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need to address any additional areas of discovery which become apparent through the course
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of discovery and litigation in this matter.
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III.
Necessity of Requested Extension of Time
While the Parties have exchanged responses to written discovery, additional discovery
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is necessary with respect to certain categories of damages claimed by Plaintiff.
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discovery may necessitate the retention of additional expert witnesses in this case. The current
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deadline for expert disclosures is July 9, 2018. Additionally, complications continue to exist
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in securing dates to depose several of the Plaintiff’s medical health care providers. The
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current deadline to complete discovery is September 6, 2018. Due to these issues, the Parties
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believe an extension as outlined below to all remaining deadlines is necessary. The Parties are
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confident the requested extension will provide a sufficient amount of time for the Parties to
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complete additional discovery as to the categories of damages claim by Plaintiff, identify all
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necessary expert witnesses, and schedule and complete all necessary depositions in this matter.
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IV.
Requested Modifications to the Scheduling Order
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The Parties stipulate and agree to modify the Joint Discovery Plain as follows:
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1.
Discovery Cutoff Date:
November 6, 2018
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2.
Expert Disclosures:
September 7, 2018
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Such
If dispositive motions are filed, the
deadline for filing the joint pretrial
October 9, 2018
order will be suspended until 30
December 10, 2018 days after decision on the dispositive
motions or further court order.
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3.
Expert Rebuttal:
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Dispositive Motions:
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Joint Pretrial Order:
January 7, 2018
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6.
Interim Status Report:
September 7, 2018
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IT IS SO AGREED this 20th day of June, 2018.
DE CASTROVERDE LAW GROUP
THORPE SHWER, P.C.
By /s/ David Menocal
David Menocal
Kimberly Valentin
Peter Peterson
1149 S. Maryland Parkway
Las Vegas, NV 89104
Attorneys for Plaintiff
By /s/ William L. Thorpe
William L. Thorpe (Pro Hac Vice)
Tyler Grim (Pro Hac Vice)
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THORPE SHWER, P.C.
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3200 North Central Avenue
Suite 1560
Phoenix, AZ 85012
Attorneys for Defendants
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MESSNER REEVES LLP
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By /s/ Renee M. Finch
Renee M. Finch, Esq.
Nevada Bar No. 13118
8945 West Russell Road, Suite 300
Las Vegas, Nevada 89148
Co-Counsel for Defendants
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ORDER
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IT IS SO ORDERED.
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DATED:
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June 20, 2018
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_______________________________
UNITED STATES MAGISTRATE JUDGE
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