De Blanc v. Aloha Airport Express, LLC

Filing 21

ORDER granting 19 Stipulation to Extend Discovery Deadlines. Discovery due by 9/24/2018. Motions due by 10/23/2018. Proposed Joint Pretrial Order due by 11/23/2018. Signed by Magistrate Judge Carl W. Hoffman on 5/1/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-00151-APG-CWH Document 19 Filed 04/27/18 Page 1 of 4

1
2
3
4
5
6

SAO
MICHAELA E. WOOD, ESQ.
Nevada Bar No. 9466
RICHARD HARRIS LAW FIRM
801 South Fourth Street
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff

7
8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11
12
13
14
15
16
17
18

SANDRA DE BLANC,

)
)
Plaintiff,
)
) CASE NO.: 2:18-cv-00151-APG-CWH
vs.
)
)
ALOHA AIRPORT EXPRESS, a Foreign Limited )
Liability Company; does 1 THROUGH 20; ROE
)
BUSINESS ENTITIES 1 through 20, inclusive
)
jointly and severally,
)
)
Defendants.
)
)

19

STIPULATION AND ORDER FOR EXTENSION OF TIME
TO COMPLETE DISCOVERY (FIRST REQUEST)

20
21

The parties stipulate to an extension of discovery deadlines, currently set pursuant to the

22
23

Stipulated Discovery Plan and Scheduling Order [Doc. #10] filed on March 7, 2018.

24

I.

25

DISCOVERY THAT HAS BEEN COMPLETED IN THIS MATTER INCLUDES
THE FOLLOWING:

26

The following discovery has been completed by the parties:

27

1. Plaintiff received written discovery;
2. Plaintiff’s Initial Disclosure;

28

1

Case 2:18-cv-00151-APG-CWH Document 19 Filed 04/27/18 Page 2 of 4

3. Defendant’s Initial 16.1 Disclosure.

1
2

II.

DISCOVERY THAT REMAINS TO BE COMPLETED:
The discovery that remains to be completed includes, but is not limited to:

3
4

1. Initial expert disclosures;

5

2. Depositions of expert witnesses

6

3. Deposition of Person(s) Most Knowledgeable for Aloha
Airport Express;

7

4. Deposition of Plaintiff;

8

5. Depositions of Plaintiff’s treating providers;

9

6. Additional written discovery requests.

10

7. Requesting and obtaining updated medical records.

11

8. Any other potential depositions or written discovery which
may become necessary as discovery continues.

12

14

REASONS WHY THE DISCOVERY REMAINING WILL NOT BE
COMPLETED WITHIN THE TIME LIMITS SET BY THE DISCOVERY
ORDER

15

The parties to this action need additional time to complete discovery. The Plaintiff lives

16

out of state and takes care of her elderly, sick husband. She has to make arrangements for

13

17

III.

somebody to stay with him while she travels back to Las Vegas for her deposition. Defense

18

counsel has been kind enough to accommodate for this and has agreed to extend any outstanding
19
20
21

deadlines.
IV.

A PROPOSED
DISCOVERY

SCHEDULE

FOR

COMPLETING

ALL

REMAINING

22

The parties hereby stipulate to continue the discovery deadlines sixty (60) days as
23
24

follows:
Old Deadline:

New Deadline:

Last day to Amend Pleadings:

04/26/2018

06/25/2018

Initial Expert Disclosures:

05/25/2018

07/24/2018

25
26
27
28

2

Case 2:18-cv-00151-APG-CWH Document 19 Filed 04/27/18 Page 3 of 4

1

05/25/2018

07/24/2018

Rebuttal Expert Disclosures:

06/25/2018

08/24/2018

Close of Discovery:

2

Interim Status Report

07/25/2018

09/24/2018

Dispositive Motion Deadline:

08/24/2018

10/23/2018

Pre-Trial Order, if no Dispositive Motions

09/24/2018

11/23/2018

3
4
5
6
7
8
9

Dated this 27th day of April, 2018

Dated this 27th day of April, 2018

By: __/s/ Michaela E. Wood____________

By: __/s/ Christopher D. Phipps________

10
11
12
13
14

RICHARD HARRIS LAW FIRM
Michaela E. Wood, Esq.
Nevada Bar No. 9466
801 S. Fourth Street
Las Vegas, NV 89101

WILSON ELSER MOSKOWITZ
& DICKER LLP
Christopher D. Phipps, Esq.
Nevada Bar No. 3788
300 S. Fourth Street, 11th Floor
Las Vegas, NV 89101

15

Attorneys for Plaintiff
Attorneys for Defendant

16
17
18
19
20
21

IT IS SO ORDERED this ____ day of April, 2018.
DATED: May 1, 2018

__________________________________
UNITED STATES DISTRICT JUDGE
MAGISTRATE JUDGE

22
23
24
25
26
27
28

3

Case 2:18-cv-00151-APG-CWH Document 19 Filed 04/27/18 Page 4 of 4

1
2
3

CERTIFICATE OF SERVICE
Pursuant to FRCP 5, I certify that I am an employee of RICHARD HARRIS LAW FIRM, and
that on this 27th day of April, 2018, I served a copy of the foregoing STIPULATION AND

4
5

ORDER FOR EXTENSION OF TIME TO COMPLETE DISCOVERY by the CM/ECF

6

electronic filing system of the United States District Court for the District of Nevada, upon each

7

party in this case who is registered as an electronic filing user with the Clerk.

8
9
10
11
12
13

WILSON ELSER MOSKOWITZ
& DICKER LLP
Christopher D. Phipps, Esq.
Nevada Bar No. 3788
300 S. Fourth Street, 11th Floor
Las Vegas, NV 89101
Attorneys for Defendant

14

/s/ Nicole Gilenson
___________________________________
An Employee of Richard Harris Law Firm

15
16
17
18
19
20
21
22
23
24
25
26
27
28

4