Perez v. Twyoford et al

Filing 25

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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1 2 3 4 5 6 7 8 9 10 THORPE SHWER, P.C. 11 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 12 UNITED STATES DISTRICT COURT 13 14 15 16 17 18 19 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, 21 23 24 25 26 27 STIPULATION TO EXTEND SCHEDULED DEADLINES (FIRST REQUEST) (Assigned to the Hon. Andrew P. Gordon) Defendants. 20 22 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 28 {02936568 / 1} 9007681 1 served their responses to Plaintiff’s written discovery on April 16, 2018. Plaintiff served her 2 responses to Defendants’ written discovery May 15, 2018. A Rule 35 examination of the 3 Plaintiff was also conducted on May 23, 2018. 4 II. Discovery Yet to be Completed Plaintiff’s deposition is currently scheduled for June 26, 2018. Additionally, the Parties 6 are still working to coordinate and schedule the depositions of (1) a corporate designee of JB 7 Transport, Inc., (2) many of Plaintiff’s medical providers, and (3) Plaintiff’s lay witnesses. As 8 detailed below, the Parties have encountered numerous complications in scheduling the 9 depositions of the medical providers. The Parties agree that additional discovery is necessary 10 to clarify certain categories of damages claimed by Plaintiff. The Parties have also not 11 THORPE SHWER, P.C. 5 exchanged expert reports or conducted any expert discovery to date. The Parties also will 12 need to address any additional areas of discovery which become apparent through the course 13 of discovery and litigation in this matter. 14 III. Necessity of Requested Extension of Time While the Parties have exchanged responses to written discovery, additional discovery 15 16 is necessary with respect to certain categories of damages claimed by Plaintiff. 17 discovery may necessitate the retention of additional expert witnesses in this case. The current 18 deadline for expert disclosures is July 9, 2018. Additionally, complications continue to exist 19 in securing dates to depose several of the Plaintiff’s medical health care providers. The 20 current deadline to complete discovery is September 6, 2018. Due to these issues, the Parties 21 believe an extension as outlined below to all remaining deadlines is necessary. The Parties are 22 confident the requested extension will provide a sufficient amount of time for the Parties to 23 complete additional discovery as to the categories of damages claim by Plaintiff, identify all 24 necessary expert witnesses, and schedule and complete all necessary depositions in this matter. 25 IV. Requested Modifications to the Scheduling Order 26 The Parties stipulate and agree to modify the Joint Discovery Plain as follows: 27 1. Discovery Cutoff Date: November 6, 2018 28 2. Expert Disclosures: September 7, 2018 {02936568 / 1} 9007681 2 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. 1 3. Expert Rebuttal: 2 4. Dispositive Motions: 3 5. Joint Pretrial Order: January 7, 2018 4 6. Interim Status Report: September 7, 2018 5 6 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) 7 8 9 10 THORPE SHWER, P.C. 11 3200 North Central Avenue Suite 1560 Phoenix, AZ 85012 Attorneys for Defendants 12 MESSNER REEVES LLP 13 14 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 15 16 17 18 ORDER 19 20 IT IS SO ORDERED. 21 DATED: 22 June 20, 2018 23 _______________________________ UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 {02936568 / 1} 9007681 3

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