De Blanc v. Aloha Airport Express, LLC

Filing 24

ORDER granting 23 Stipulation re Discovery. Discovery due by 11/23/2018. Motions due by 12/21/2018. Proposed Joint Pretrial Order due by 1/22/2019. Signed by Magistrate Judge Carl W. Hoffman on 8/24/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-00151-APG-CWH Document 23 Filed 08/22/18 Page 1 of 4

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IAN C. ESTRADA, ESQ.
Nevada Bar No. 12575
RICHARD HARRIS LAW FIRM
801 South Fourth Street
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [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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SANDRA DE BLANC,

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CASE NO.: 2:18-cv-00151-APG-CWH

Plaintiff,

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vs.
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ALOHA AIRPORT EXPRESS, a Foreign
Limited Liability Company; DOES 1 through 20;
ROE BUSINESS ENTITIES 1 through 20,
inclusive jointly and severally,

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

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Defendants.

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Plaintiff, SANDRA DE BLANC, and Defendant, ALOHA AIRPORT EXPRESS, by

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and through their respective counsel, and pursuant to Local Rule 26-4, stipulate to modify their

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discovery plan as follows:

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1.

Plaintiff filed her Complaint in the Eighth Judicial District Court for Clark

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County, Nevada on October 20, 2017.

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January 26, 2018 (ECF No. 1).

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2.

Defendant removed the action to this Court on

The parties held their F.R.C.P. 26 conference on March 5, 2018 and filed their

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initial Stipulated Discovery Plan and Scheduling Order in compliance with F.R.C.P. 26(f) and

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LR 26-1(e) on March 7, 2018 (ECF No. 16). The parties filed a Stipulation and Order for

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Extension of Time to Complete Discovery (First Request) on April 27, 2018. In the first
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Case 2:18-cv-00151-APG-CWH Document 23 Filed 08/22/18 Page 2 of 4

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Stipulation for the extension of the discovery deadlines, the parties agreed to the following

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dates:

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Last day to Amend Pleadings/Add Parties:

June 25, 2018

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Initial Expert Disclosure:

July 24, 2018

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Joint Interim Status Report:

July 24, 2018

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Rebuttal Expert Disclosure:

August 24, 2018

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Discovery Cut Off:

September 24, 2018

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Dispositive Motions:

October 23, 2018

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Joint Pre-Trial order:

November 23, 2018

The Stipulation and Order for Extension of Time to Complete Discovery (First Request)

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was signed by United States Magistrate Judge Carl W. Hoffman on May 1, 2018 (ECF No. 21).
3.

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In compliance with Local Rule 26-4, the parties provide the following

information regarding the discovery status:
a.

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Discovery Completed: The parties have exchanged initial disclosures of

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witnesses and documents, have served written discovery, Plaintiff’s deposition has been taken

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and the parties have exchanged initial expert disclosures.
b.

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Discovery that remains to be completed: Additional time is needed for

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Defendant to schedule and conduct the depositions of Plaintiff’s expert witnesses

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William Muir, M.D. and Lane Swainston and Plaintiff to schedule and conduct the depositions

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of Defendant’s driver Daniel Leivas and Defendant’s FRCP 30(b)(6) witness Michael Logan,

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both of whose depositions must be taken out-of-state in Arizona. No further discovery is

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anticipated at this time; however, additional discovery may be required based upon the

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deposition testimony of those witnesses. The parties have been diligently working with each

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other and co-operating with discovery requests as necessary. Based on the foregoing, the

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parties are requesting additional time to complete the discovery set forth above.

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///

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///
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Case 2:18-cv-00151-APG-CWH Document 23 Filed 08/22/18 Page 3 of 4

c.

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Reasons why discovery was not completed: There is good cause for a

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sixty (60) day extension of the discovery cutoff deadline. Counsel have been working diligently

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to attempt to adhere to the current discovery time lines. However, due to the congested

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schedules of counsel, including trial obligations, the parties require additional time to conclude

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the limited discovery set forth above. Thus, the request for additional time is being requested.

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The instant request is not made for purposes of delay. The parties are working diligently to

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complete all remaining discovery.
d.

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Proposed schedule for completion of remaining discovery (extension of

remaining deadlines by sixty 60 days):

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Last day to Amend Pleadings/Add Parties:

CLOSED

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Initial Expert Disclosure:

CLOSED

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Joint Interim Status Report:

CLOSED

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Rebuttal Expert Disclosure:

CLOSED

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Discovery Cut Off:

November 23, 2018

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Dispositive Motions:

December 21, 2018

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Joint Pre-Trial order:

January 22, 2019

SUBMITTED BY THE FOLLOWING COUNSEL OF RECORD:

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DATED this 22nd day of August, 2018.

DATED this 22nd day of August, 2018.

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RICHARD HARRIS LAW FIRM

WILSON ELSER MOSKOWITZ EDELMAN &
DICKER, LLP

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/s/ Ian C. Estrada

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By:
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/s/ Christopher D. Phipps
By:

IAN C. ESTRADA, ESQ.
Nevada Bar No. 12575
801 South Fourth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff

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MICHAEL LOWRY, ESQ.
Nevada Bar No. 10666
CHRISTOPHER D. PHIPPS, ESQ.
Nevada Bar No. 3788
300 South Fourth Street, 11th Floor
Las Vegas, Nevada 89101
Attorneys for Defendant
ALOHA AIRPORT EXPRESS, LLC

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///
August 24, 2018
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Case 2:18-cv-00151-APG-CWH Document 23 Filed 08/22/18 Page 4 of 4

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IT IS SO ORDERED:

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____________________________________
UNITED STATES MAGISTRATE JUDGE
DATED: ______________________

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