Hellman v. Greystone Nevada, LLC et al

Filing 17

ORDER granting 16 Stipulation to Extend Deadlines. Discovery due by 9/6/2021. Motions due by 10/4/2021. Proposed Joint Pretrial Order due by 11/5/2021. Signed by Magistrate Judge Brenda Weksler on 3/26/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00559-JCM-BNW Document 16 Filed 03/22/21 Page 1 of 3
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03/26/21

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J. NATHAN OWENS, ESQ. SBN 12843
AMTOJ S. RANDHAWA, ESQ. SBN 13746
NEWMEYER & DILLION LLP
3800 Howard Hughes Pkwy, Suite 700
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants,
GREYSTONE NEVADA, LLC;
LENNAR SALES CORP.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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PETER J. HELLMAN,
Plaintiff,

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CASE NO.: 2:20-cv-00559-JCM-BNW
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DISCOVERY
DEADLINES

vs.
GREYSTONE NEVADA, LLC.;
LENNAR SALES CORP.; DOES 1
through X; and ROE CORPORATIONS
XI through XXXI, inclusive,

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[THIRD REQUEST]

Defendants.

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Defendants GREYSTONE NEVADA, LLC and LENNAR SALES CORP.

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(collectively “Defendants”), by and through their counsel of record, Amtoj S. Randhawa,
Esq. of the law firm of Newmeyer & Dillion LLP, and Plaintiff PETER J. HELLMAN
(“Plaintiff”), by and through his counsel of record, John B. Greene, Esq. of Vannah &
Vannah, HEREBY STIPULATE pursuant to LR IA 6-1, and request the Court to extend all
remaining discovery deadlines by 70 days, as set forth herein.
These extensions are requested in light of Plaintiff’s recent infection with the

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COVID-19 virus and consequent inability to appear for his Independent Medical
Examination (“IME”), currently scheduled for Tuesday, March 23, 2021.
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1708.599 / 9239936.1

Case 2:20-cv-00559-JCM-BNW Document 16 Filed 03/22/21 Page 2 of 3
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Good cause exists to grant the relief requested herein given that Plaintiff has tested

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positive for COVID-19 and cannot appear for his currently-scheduled IME. As a result,

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Defendants’ experts are unable to evaluate Plaintiff and prepare expert reports before the

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currently-scheduled expert disclosure deadline, and the earliest date on which the IME

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can be rescheduled is May 25, 2020.

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The parties have been working diligently to conduct discovery, and as of the date
of this stipulation, the parties have completed the following discovery:
(1)

Plaintiff has served responses to Defendants’ special interrogatories and

requests for production of documents;
(2)

Defendants have served responses to Plaintiff’s special interrogatories and

requests for production of documents;

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(3)

Defendants have completed the deposition of Plaintiff Peter Hellman;

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(4)

Defendants have completed the deposition of Lars Bangen;

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(5)

Defendants have completed the deposition of Amanda Hellman;

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(6)

Plaintiff has completed the deposition of Thomas Dome;

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(7)

Plaintiff has completed the deposition of FRCP 30(b)(6) witness for

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Greystone Nevada, LLC;

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(8)

Plaintiff has completed the deposition of Melissa Flores; and

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(9)

Plaintiff has completed the deposition of FRCP 30(b)(6) witness for Lennar

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Sales Corp.

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In light of the circumstances set forth above, the parties hereby stipulate and

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request to continue the dates set forth in the Court’s Scheduling Order (ECF 15) as follows:

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1.

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6, 2021;

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2.

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That the discovery cut-off be extended from June 28, 2021 to September

That the time for parties to file any motions to amend the pleadings and/or

add parties to this action be extended from March 29, 2021 to June 7, 2021;
3.

That the disclosure of experts and their reports shall be extended from April

27, 2021 to July 6, 2021;
1708.599 / 9239936.1

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Case 2:20-cv-00559-JCM-BNW Document 16 Filed 03/22/21 Page 3 of 3
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03/26/21

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4.

The disclosure of rebuttal experts and their reports shall be extended from

May 26, 2021 to August 4, 2021;
5.

That the time for parties to file Dispositive Motions shall be extended from

July 26, 2021 to October 4, 2021;
6.

That the time for parties to prepare a Consolidated Pre-Trial Order shall be

extended from August 27, 2021 to November 5, 2021; and
7.

That the time for parties to stipulate or move to extend the discovery cutoff

be extended from June 2, 2021 to August 11, 2021.

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Dated: this 22nd day of March, 2021

NEWMEYER & DILLION LLP

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By:

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J. NATHAN OWENS, ESQ. SBN 12843
AMTOJ S. RANDHAWA, ESQ. SBN 13746
3800 Howard Hughes Pkwy, Suite 700
Las Vegas, Nevada 89169

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Attorneys for Defendants GREYSTONE
NEVADA, LLC; LENNAR SALES CORP.

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Dated: this 22nd day of March, 2021

VANNAH & VANNAH

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By: /s/ John B. Greene
JOHN B. GREENE, ESQ. SBN 4279
ROBERT D. VANNAH, ESQ. SBN 2503
400 S. Seventh St., 4th Floor
Las Vegas, Nevada 89101

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Attorneys for Plaintiff, PETER J. HELLMAN

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IT IS SO ORDERED:

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DATED: 10:59 am, March 26, 2021

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ORDER
IT IS SO ORDERED

Date: ___________________, 2021

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__________________________________

BRENDA WEKSLER UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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1708.599 / 9239936.1

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