Bryant v Madison Management Services, LLC, et al

Filing 54

ORDER granting 53 Stipulation; Discovery due by 12/8/2021. Motions due by 1/4/2022. Proposed Joint Pretrial Order due by 2/3/2022. Signed by Magistrate Judge Elayna J. Youchah on 7/15/2021. (Copies have been distributed pursuant to the NEF - DRS)

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George Haines, Esq.
Nevada Bar No. 9411
FREEDOM LAW FIRM
8985 S. Eastern Avenue, Ste. 350
Beltway Corporate Center
Las Vegas, NV 89123
Telephone: [phone]
[e-mail]
Counsel for Plaintiff Lisa A. Bryant
Marc E. Dann, Esq.
Ohio Bar No. 44115 (admitted pro hac)
DANN LAW FIRM
2728 Euclid Avenue, STE 300
Cleveland, OH 44115
Telephone: [phone]
[e-mail]
Counsel for Plaintiff Lisa A. Bryant

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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LISA A. BRYANT,

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Plaintiff,
v.
MADISON MANAGEMENT SERVICES,
LLC, and WALDMAN & PORRAS, PLLC,
Defendants.

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Case No.: 2:20-cv-00594-JAD-EJY

[PROPOSED] STIPULATION AND
ORDER TO EXTEND DISCOVERY
[SECOND REQUEST]

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Pursuant to Fed. R. Civ. P. 26(f), and Local Rule 26-1, Plaintiff, Lisa Bryant, and Defendants,

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Madison Management Services, LLC, and Waldman & Porras, PLLC, (collectively known as the

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“Parties) by and through their attorneys, hereby stipulate to stay all discovery deadlines and other
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deadlines in the February 1, 2021 Scheduling Order (ECF No. 39) as follows:
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Completed Discovery.

The parties have exchanged initial disclosures. Parties have served written discovery.
2.

Remaining Discovery.

Written discovery responses from Plaintiff and the parties’ depositions.
3. Good Cause.

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A Discovery Plan and Scheduling Order was approved by the Court on February 1, 2021.

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(ECF No. 39). On February 25, 2021, the Court approved a Stipulation and Order to Stay

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Discovery and Schedule Settlement Conference. (ECF NO. 41). The Court entered an Order

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Setting Settlement Conference on February 26, 2021, which, among other things, scheduled a

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mediation conference for March 30, 2021. (ECF No. 42). On March 25, 2021, the Court approved

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an Agreed Stipulation for Continuance of Settlement Conference and Due Date for Confidential

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Settlement Statement, which, among other things, scheduled a mediation conference for June 11,

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2021. (ECF NO. 43). The parties attended the mediation on that day, but were unable to agree to

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a resolution. Regarding the proposed discovery deadlines, the Parties have used the June 11, 2021

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mediation conference as the date to calculate the proposed discovery deadlines. This stipulation
is made in good faith, is not interposed for delay, and is not filed for an improper purpose.
Furthermore, a trial date has not been set at this time.

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4. Current Discovery Deadlines.
 Discovery Cutoff: August 5, 2021
 Deadline to Amend Pleadings: May 17, 2021
 Deadline to Disclose Initial Expert Disclosures: June 16, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: July 17, 2021
 Dispositive Motion Deadline: September 15, 2021

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 Joint Proposed Pretrial Order: October 16, 2021

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5.

Proposed Discovery Deadlines.

 Discovery Cutoff: December 8, 2021
 Deadline to Amend Pleadings: September 9, 2021
 Deadline to Disclose Initial Expert Disclosures: October 11, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: November 10, 2021
 Dispositive Motion Deadline: January 4, 2022
 Joint Proposed Pretrial Order: February 3, 2022
WHEREAS, no prejudice will occur to this Court or the Parties if granted, good cause
supports this request to extend discovery;
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NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS
HEREBY STIPULATED AND AGREED, by and between the Parties as follows:
The February 1, 2021 Scheduling Order (ECF No. 39) shall be amended as follows:
 Discovery Cutoff: December 8, 2021
 Deadline to Amend Pleadings: September 9, 2021
 Deadline to Disclose Initial Expert Disclosures: October 11, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: November 10, 2021
 Dispositive Motion Deadline: January 4, 2022
 Joint Proposed Pretrial Order: February 3, 2022
IT IS SO STIPULATED.
DATED: February 22, 2021

DATED: February 22, 2021

FREEDOM LAW FIRM, LLC

WALDMAN & PORRAS, PLLC

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By: /s/ George Haines
GEORGE HAINES, ESQ.
Nevada Bar No.: 9411
8985 S. Eastern Ave., Suite 350
Las Vegas, NV 89123
Attorney for Plaintiff
LISA BRYANT

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By: /s/Nicolas M. Porras
NICOLAS M. PORRAS, ESQ.
Nevada Bar No.: 12849
201 West Liberty Street, Suite 207
Reno, NV 89501
Attorney for Defendants
MADISON MANAGEMENT SERVICES,
LLC, AND PORRAS, PLLC

DANN LAW FIRM

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By:/s/ Marc E. Dann____
Marc E. Dann, Esq.
Ohio Bar No. 44115 (admitted pro hac)
2728 Euclid Avenue, STE 300
Cleveland, OH 44115
Counsel for Plaintiff Lisa A. Bryant

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ORDER GRANTING
STIPULATION TO EXTEND DISCOVERY
In consideration of the parties’ stipulation and good cause showing, IT IS ORDERED
THAT the February 1, 2021 Scheduling Order shall be amended as follows:
 Discovery Cutoff: December 8, 2021
 Deadline to Amend Pleadings: September 9, 2021
 Deadline to Disclose Initial Expert Disclosures: October 11, 2021
 Deadline to Disclose Rebuttal Expert Disclosures: November 10, 2021
 Dispositive Motion Deadline: January 4, 2022
 Joint Proposed Pretrial Order: February 3, 2022

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IT IS SO ORDERED.
________________________________________
UNITED STATES MAGISTRATE JUDGE

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Dated: July 15, 2021

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