Reeves v. Discover Your Mobility, Inc. et al

Filing 40

SCHEDULING ORDER granting 38 Discovery Plan and Scheduling Order. Discovery due by 9/17/2024. Motions due by 10/17/2024. Proposed Joint Pretrial Order due by 11/18/2024. Signed by Magistrate Judge Daniel J. Albregts on 6/3/2024. (Copies have been distributed pursuant to the NEF - MAM)

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BRADLEY S. MAINOR, ESQ.
Nevada Bar No. 7434
ADAM ELLIS, ESQ.
Nevada Bar No. 14514
MAINOR ELLIS, LLP
8367 W. Flamingo Road, Suite 200
Las Vegas, Nevada 89147
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ELLEN REEVES, individually,

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CASE NO: 2:22-cv-01361-GMN-DJA

Plaintiff,

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vs.

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DISCOVER YOUR MOBILITY, INC., a
foreign
corporation;
SOLO
WORLD
PARTNERS, LLC, a foreign limited liability
company;
DOE
EMPLOYEES
I-V,
individually; DOE MANAGERS I-V,
individually; ROE MANUFACTURERS I-X;
ROE INSPECTION COMPANIES I-V; ROE
DISTRIBUTORS I-X; DOE INDIVIDUALS
I-X; and ROE BUSINESS ENTITIES I-X,
inclusive,

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RENEWED DISCOVERY PLAN AND
[PROPOSED] SCHEDULING ORDER
SPECIAL SCHEDULING REVIEW
REQUESTED

Defendants.

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Plaintiff ELLEN REEVES, by and through her counsel of record ADAM ELLIS, ESQ.;
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Discovery Your Mobility, Inc., by and through its counsel of record ADAM KNECHT, ESQ., and
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SOLO WORLD PARTNERS, LLC, by and through its counsel of record JOHN KRIEGER,
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ESQ.. hereby submit their Renewed Discovery Plan and Scheduling Order pursuant to Fed R.
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Civ. P. 26(f) and Local Rule 26-1, as Defendant Solo World Partners, LLC recently appeared in
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the case.
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I.

REASON FOR SPECIAL SCHEDULING REVIEW

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This case is relatively unusual, as Defendant Solo World Partners appeared in the case the
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day before discovery was to be completed. Plaintiff added Defendant Solo World via Motion, and

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the discovery period waned while Plaintiff effectuated service of process and while Defendant

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Solo World filed a responsive pleading. Thus, the parties seek discovery to be reopened.

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II.

ESTIMATED TIME REQUIRED FOR DISCOVERY:

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The parties believe one-hundred twenty days from the date of submission is sufficient to

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complete any remaining discovery, namely by and regarding Defendant Solo World Partners,
The Discovery Cutoff will be September 17,
LLC, as it appeared in the case on March 21, 2024.
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III.
AMENDING THE PLEADINGS AND ADDING PARTIES:

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This deadline has passed, and the parties do not believe it is necessary to extend this deadline.
IV.

FED. R. CIV. P. 26(A)(2) EXPERT DISCLOSURES:

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In accordance with Fed. R. Civ. P. 26(a)(2), disclosures identifying experts shall be made 60

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days prior to the discovery cutoff date. The deadline will be July 19, 2024 for Defendant Solo

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World, as the deadline to disclose experts for Plaintiff and Defendant Discover Your Mobility,

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Inc. has already passed.

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The parties believe the deadline for Rebuttal Expert Disclosures should be thirty (30) days
after the deadline for initial disclosures, making the deadline August 19, 2024.
V.

DISPOSITIVE MOTIONS:
The parties shall file dispositive motions 30 days after the discovery cutoff date, and

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therefore, not later than October 17, 2024.

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VI.

PRETRIAL ORDER:

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If no dispositive motions are filed, and unless otherwise ordered by this Court, the Joint

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Pretrial Order shall be filed 30 days after the date set for filing dispositive motions, and therefore,

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not later than November 18, 2024.

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In the event dispositive motions are filed, the date for filing the Joint Pretrial Order shall be

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suspended until 30 days after the Court enters a ruling on dispositive motions, or otherwise by

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further Court order. The disclosures required by Fed. R. Civ. P. 26(a)(3), and any objections

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thereto, shall be included in the Joint Pretrial Order.

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VII.

ALTERNATIVE DISPUTE RESOLUTION:

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The parties certify that they met and conferred about the possibility of using alternative

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dispute resolution processes including mediation or arbitration. While the parties are open to

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various means of resolution, they agree additional discovery must be obtained prior to scheduling

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any kind of settlement conference. However, the parties will continue the informal settlement

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discussions underway.

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ALTERNATIVE FORMS OF CASE DISPOSITION:

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The parties hereby certify that they considered consent to trial by a magistrate judge under 28

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U.S.C. § 636(c) and Fed. R. Civ. P. 73, use of the Short Trial Program (General Order 2013-01).

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The parties have not agreed to trial by a magistrate judge or the use of the short trial program, at

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this time.

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IX.

ELECTRONIC EVIDENCE:

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The parties did not come to any stipulations regarding providing discovery in an electronic

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format, and will evaluate the need for special procedures for electronic evidence should the need

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arise.

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MAINOR ELLIS, LLP

HALL & EVANS, LLC

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/s/ Adam Ellis
BRADLEY S. MAINOR, ESQ.
Nevada Bar No. 7434
ADAM ELLIS, ESQ.
Nevada Bar No. 14514
8367 W. Flamingo Road, Suite 200
Las Vegas, Nevada 89147
Attorneys for Plaintiff

/s/ Adam Knecht
ADAM R. KNECHT, ESQ.
1160 North Town Center Drive, Suite 330
Las Vegas, NV 89144
Attorneys for Def. Discover Your Mobility, Inc.

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DICKINSON WRIGHT PLLC
/s/ John Krieger
Nevada Bar No. 6023
3883 Howard Hughes Parkway, Suite 800
Las Vegas, Nevada 89169
Email: [e-mail]
Attorneys for Def. Solo World Partners, LLC

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IT IS THEREFORE ORDERED that the parties' stipulated discovery plan (ECF No. 38) is
GRANTED IT IS SO ORDERED:
____________________________________
____________________________________
UNITED
MAGISTRATE JUDGE
DANIEL J.STATES
ALBREGTS
UNITED STATES MAGISTRATE JUDGE
DATED: 6/3/2024
___________

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