Muric-Dorado v. LVMPD et al

Filing 191

ORDER Extending Deadlines - Discovery due by 7/6/2022. Motions due by 8/5/2022. Proposed Joint Pretrial Order due by 9/5/2022. Signed by Magistrate Judge Elayna J. Youchah on 1/7/2022. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:18-cv-01184-JCM-EJY Document 191 Filed 01/07/22 Page 1 of 3

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CHARLES R. GOODWIN, ESQ.
Nevada Bar No. 14879
GOODWIN LAW GROUP , PLLC
3100 W Charleston Blvd
Las Vegas, NV 89102
Telephone [phone]
[e-mail]
Attorney for plaintiff Ramon Muric-Dorado

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
RAMON MURIC-DORADO,

CASE NO. 2:18-cv-01184-JCM-EJY

Plaintiff,
v.
LVMPD, et. al.,

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STIPULATION AND
DISCOVERY

Defendants.

ORDER TO EXTEND

(FIRST REQUEST)

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IT IS HEREBY STIPULATED AND AGREED between the parties, through their

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counsel of record, to extend discovery for good cause shown pursuant to LR IA 6-1. The parties

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agree to extend discovery deadlines in this matter past their current deadlines. This is the second

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stipulation for extension of time to conduct discovery.

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DISCOVERY COMPLETED TO DATE
The parties have completed the following discovery:

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1.

Defendants served their initial FRCP 26 disclosures.

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2.

Plaintiff served their initial FRCP 26 disclosures.

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DISCOVERY THAT REMAINS TO BE COMPLETED

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1.

Plaintiffs need to serve written discovery requests on defendants.

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2.

Potential deposition of parties and third parties.

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3.

Designate experts.

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4.

Any additional discovery the parties deem necessary.
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Case 2:18-cv-01184-JCM-EJY Document 191 Filed 01/07/22 Page 2 of 3

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REASONS WHY DISCOVERY COULD NOT BE COMPLETED

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WITHIN THE PARAMETERS OF THE DISCOVERY SCHEDULING ORDER

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Plaintiff’s counsel has been severely limited in his ability to speak with plaintiff.

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Specifically, plaintiff is only allowed to visit with counsel on Monday mornings at 11am for two

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hours. It has been difficult for plaintiff’s counsel to retrieve documents, review discovery, and

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obtain signatures from plaintiff because the timeframe for visitation conflicts with mandated

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court appearances.

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Plaintiff’s counsel is pro-bono and does not have the same access to funds as traditional

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parties in civil suits. It is taking longer to attempt to locate an expert that would be willing to

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work on reduced fees while at the same time attempting to locate programs that can help

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supplement expert fees.
PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY

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Close of discovery:
Final dates for expert disclosures:
i.
Initial disclosures:
ii.
Rebuttal disclosures:
Final date to file dispositive motions:
Joint Pretrial Order filing deadline

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Current
3/7/22

Proposed
7/6/22

1/6/22
2/7/22
3/2/22
1/3/22

4/6/22
5/7/22
8/5/22
9/5/22

Case 2:18-cv-01184-JCM-EJY Document 191 Filed 01/07/22 Page 3 of 3

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DATED this 5th day of January 2022.

DATED this 5th day of January 2022.

GOODWIN LAW GROUP, PLLC

KAEMPFER CROWELL

By: /s/ Charles R Goodwin____
Charles R. Goodwin, Esq.
Nevada Bar No. 14879
3100 W Charleston Blvd
Las Vegas, NV 89102
Telephone [phone]
[e-mail]
Attorney for plaintiff Ramon MuricDorado

By: /s/Lyssa S. Anderson____
Lyssa S. Anderson, Esq.
Nevada Bar No. 5781
Ryan W. Daniels, Esq.
Nevada Bar No. 13094
Kristopher John Kalkowski, Esq.
Nevada Bar No. 14892
1980 Festival Plaza Dr. Suite 650
Las Vegas, NV 89135
Telephone [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant LVMPD

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DATED this 5th day of January 2022.
LAURIA TOKUNAGA GATES & LINN,
LLP

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By: /s/ Paul A Cardinale
Paul A. Cardinale
1755 Creekside Oaks Dr., Ste 240
Sacramento, CA 95833
916-492-2000
916-492-2500 (fax)
[e-mail]
Attorney for Defendant NaphCare,
Inc.

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ORDER

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IT IS SO ORDERED.

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_____________________________________
UNITED STATES MAGISTRATE JUDGE

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Dated: January 7, 2022
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