Hellman v. Greystone Nevada, LLC et al

Filing 60

ORDER Granting 59 Stipulation - Discovery due by 3/7/2022. Motions due by 4/6/2022. Proposed Joint Pretrial Order due by 5/6/2022. Signed by Magistrate Judge Brenda Weksler on 1/3/2022. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 1 of 6
60
01/03/22

1 GEORGE F. HAND, ESQ.
Nevada State Bar No. 8483
2 [e-mail]
HAND & SULLIVAN, LLC
3 3442 North Buffalo Drive
Las Vegas, Nevada 89129
4 Telephone: [phone]
Facsimile: [phone]
5
Attorney for Third-Party Defendant
6 AMANDA HELLMAN
7

UNITED STATES DISTRICT COURT

8

DISTRICT OF NEVADA

9 PETER J. HELLMAN,
10
11

CASE NO.: 2:20-cv-00559-JCM-BNW

Plaintiff,
vs.

STIPULATION AND [PROPOSED] ORDER
TO EXTEND DISCOVERY DEADLINES

12 GREYSTONE NEVADA, LLC; LENNAR
SALES CORP.; DOES I-X, inclusive, and ROE [FIFTH REQUEST]
13 CORPORATIONS XI-XX, inclusive,
14

Defendants.

15 GREYSTONE NEVADA, LLC; and LENNAR
SALES CORP.,
16
Third-Party Plaintiffs,
17
vs.
18 AMANDA HELLMAN,
19

Third-Party Defendant.

20
21

Third-Party Defendant AMANDA HELLMAN, by and through her attorney of record,

22 George F. Hand, Esq. of HAND & SULLIVAN, LLC, Plaintiff PETER J. HELLMAN, by and
23 through his attorney of record, John B. Greene, Esq. of VANNAH & VANNAH, and
24 Defendant/Third-Party Plaintiffs GREYSTONE NEVADA, LLC and LENNAR SALES CORP.,
25 by and through their attorneys of record, Amtoj S. Randhawa, Esq. and J. Nathan Owens, Esq. of
26 NEWMEYER & DILLION LLP, hereby stipulate pursuant to LR IA 6-1, and request the Court to
27 extend all remaining discovery deadlines by 60 days, as set forth herein.
28 / / /

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 2 of 6
60
01/03/22

1

This is the fifth stipulation for the extension of time for discovery. Good cause exists for

2 the requested extension given that Third-Party Defendant AMANDA HELLMAN recently
3 appeared in this action on July 28, 2021, only five months ago. Considering the complex nature of
4 this case, Mrs. HELLMAN needs additional time to depose witnesses and propound written
5 discovery in order to effectively defend herself against the claims asserted by Defendants/Third6 Party Plaintiffs GREYSTONE NEVADA, LLC (“Greystone”) and LENNAR SALES CORP.
7 (“Lennar”).
8

The parties have been working diligently to continue to conduct discovery and believe it

9 judicious to extend the discovery deadlines to allow AMANDA HELLMAN to properly conduct
10 discovery subsequent to her appearance in this case. Therefore, the Parties respectfully request a
11 60-day extension of all current discovery deadlines.
12

As of the date of this Stipulation, the parties have completed the following discovery:

13

a.

All parties have exchanged initial disclosures per FRCP 26(a);

14

b.

Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its First

15

Set of Special Interrogatories and Requests for Production of Documents and

16

Plaintiff Peter Hellman served Responses to same;

17

c.

Plaintiff Lennar’s First Set of Requests for Production;

18
19

Plaintiff Peter Hellman served Supplemental Responses to Defendant/Third-Party

d.

Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Lennar with its First

20

Set of Requests for Admission, Requests for Production, and Interrogatories and

21

Defendant Lennar served Responses to same;

22

e.

Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Greystone with its

23

First Set of Interrogatories, Requests for Admission, and Requests for Production

24

and Defendant Greystone served Responses to same;

25

f.

Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its

26

Second Set of Requests for Production of Documents and Special Interrogatories

27

and Plaintiff Peter Hellman responded to same;

28
2

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 3 of 6
60
01/03/22

1

g.

Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Lennar with its

2

Second Set of Requests for Production and Defendant Lennar served Responses to

3

same;

4

h.

Defendant/Third-Party Plaintiff Lennar served Third-Party Defendant Amanda

5

Hellman with its First Set of Requests for Production of Documents and Special

6

Interrogatories and Third-Party Defendant Amanda Hellman served Responses to

7

same;

8

i.

Third-Party Defendant Amanda Hellman made a Demand for Prior Pleadings and

9

Discovery to Defendants/Third-Party Plaintiffs Lennar and Greystone and

10

Defendants/Third-Party Plaintiffs Lennar and Greystone served a Response to same;

11

j.

Defendant/Third-Party Plaintiff Lennar served Third-Party Defendant Amanda

12

Hellman with its Second Set of Requests for Production of Documents and Third-

13

Party Defendant Amanda Hellman served Responses to same;

14

k.

Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its Third

15

Set of Requests for Production of Documents and Plaintiff Peter Hellman served

16

Responses to same;

17

l.

Third-Party Defendant Amanda Hellman served Third-Party Plaintiffs Lennar and

18

Greystone with its First Set of Requests for Production of Documents and

19

Interrogatories and Third-Party Plaintiffs Lennar and Greystone served Responses to

20

same;

21

m.

Peter Hellman’s Second Set of Requests for Production of Documents;

22
23

Defendant/Third-Party Plaintiff Lennar served Supplemental Responses to Plaintiff

n.

Defendant/Third-Party Plaintiff Greystone served Plaintiff Peter Hellman with its

24

First Set of Requests for Production of Documents and Interrogatories and Plaintiff

25

Peter Hellman served Responses to same;

26
27

o.

Third-Party Defendant Amanda Hellman and Defendants/Third-Party Plaintiffs
Lennar and Greystone met and conferred regarding various discovery issues;

28
3

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 4 of 6
60
01/03/22

1

p.

Greystone with its First Set of Supplemental Interrogatories;

2
3

q.

r.

s.

t.

u.

v.

w.

x.

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
deposition of Dr. Jessica Knirk;

18
19

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
Independent Medical Evaluation (“IME”) of Plaintiff Peter Hellman;

16
17

Plaintiff Peter Hellman has completed the deposition of Melissa Flores individually
and as the FRCP 30(b)(6) witness for Defendant/Third-Party Plaintiff Lennar;

14
15

Plaintiff Peter Hellman has completed the deposition of Thomas Dome individually
and as the FRCP 30(b)(6) witness for Defendant/Third-Party Plaintiff Greystone;

12
13

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
deposition of Dr. Kimberly Adams;

10
11

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
deposition of Third-Party Defendant Amanda Hellman;

8
9

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
deposition of Lars Bangen;

6
7

Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the
deposition of Plaintiff Peter Hellman;

4
5

Third-Party Defendant Amanda Hellman served Third-Party Plaintiffs Lennar and

y.

Defendants/Third-Party Plaintiffs Lennar and Greystone served their Initial Expert
Disclosures;

20
21

z.

Plaintiff Peter Hellman served his Initial Expert Disclosures; and

22

aa.

Defendants/Third-Party Plaintiffs Lennar and Greystone served their Rebuttal

23

Expert Disclosures.

24 / / /
25 / / /
26 / / /
27 / / /
28 / / /
4

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 5 of 6
60
01/03/22

1

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

2 continue the dates set forth by the Court as follows:
3

CURRENT DISCOVERY DEADLINES

Current

Joint Proposed
Amended

1.

Close of Discovery

01/06/2022

03/07/2022

2.

Final Date to File Motions to
10/08/2021

No Change

4
5
6

Amend Pleadings or Add Parties

7
8

3.

Final Dates for Expert Disclosures
(a)

10
11
12

Initial Disclosures

11/07/2021

No Change

(b)

9

Rebuttal Disclosures

12/07/2021

No Change

4.

Dispositive Motions

02/05/2022

04/06/2022

5.

Joint Pretrial Order

03/07/2022

05/06/2022

13
ORDER

14
15
16
17
18

Upon Stipulation of the parties;
IT IS HEREBY ORDERED that the discovery deadlines be extended as follows:
1.

Close of Discovery

2.

Final Date to File Motions to
Amend Pleadings or Add Parties

19
20

3.

25

Final Dates for Expert Disclosures
Initial Disclosures

11/07/2021

(b)

22

24

Rebuttal Disclosures

12/07/2021

4.

Dispositive Motions

04/06/2022

5.

Joint Pretrial Order

05/06/2022
ORDER
IT IS SO ORDERED

26
27

10/08/2021

(a)

21

23

03/07/2022

DATED: 12:03 pm, January 03, 2022

BRENDA WEKSLER
UNITED STATES MAGISTRATE JUDGE

28
5

Case 2:20-cv-00559-JCM-BNW Document 59 Filed 12/29/21 Page 6 of 6
60
01/03/22

1 Dated: December 29, 2021

Dated: December 29, 2021

2
/s/ George F. Hand
3 George F. Hand, Esq.
Nevada State Bar No. 8483
4
HAND & SULLIVAN, LLC
5 3442 North Buffalo Drive
Las Vegas, Nevada 89129
6 Attorneys for Third-Party Defendant
AMANDA HELLMAN
7

/s/ Amtoj Randhawa
Amtoj S. Randhawa, Esq.
Nevada State Bar No. 13746
J. Nathan Owens, Esq.
Nevada State Bar No. 12843
NEWMEYER & DILLION LLP
6725 Via Austi Pkwy, Ste. 260
Las Vegas, Nevada 89119
Attorneys for Defendant/Third-Party Plaintiffs
GREYSTONE NEVADA, LLC and
LENNAR SALES CORP

8
9

Dated: December 29, 2021

10
11
12
13
14

/s/ John B. Greene
John B. Greene, Esq.
Nevada State Bar No. 4279
VANNAH & VANNAH
400 S. Seventh St., 4th Floor
Las Vegas, Nevada 89101
Attorneys for Plaintiff
PETER J. HELLMAN

15
16
17
18
19

IT IS SO ORDERED:

20

DATED: ___________________________

21
22
23

______________________________________
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28
6