Davis v. The State of Nevada et al

Filing 41

ORDER granting 38 Stipulation for Revised Scheduling Order. Discovery due by 10/30/2024. Motions due by 11/29/2024. Proposed Joint Pretrial Order due by 12/30/2024. Signed by Magistrate Judge Daniel J. Albregts on 5/8/2024. (Copies have been distributed pursuant to the NEF - MAM)

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Rene L. Valladares
Federal Public Defender
Nevada State Bar No. 11479
*Ryan Norwood
Assistant Federal Public Defender
New Hampshire Bar #15604
411 E. Bonneville Ave., Ste. 250
Las Vegas, Nevada 89101
[phone]
[e-mail]
*Amelia Bizzaro
Assistant Federal Public Defender
Wisconsin State Bar No. 1045709
411 E. Bonneville Ave., Ste. 250
Las Vegas, Nevada 89101
[phone]
[e-mail]
*Attorneys for Petitioner James Davis

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U NITED S TATES D ISTRICT C OURT
D ISTRICT OF N EVADA

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James Anthony Davis,
Plaintiff,

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v.
Michael Minev, et al.,

Case No. 2:22-cv-01796-RFB-DJA
Stipulation for Revised Scheduling
Order

Defendants.

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Pursuant to FRCP 16(b)(4) and Local Rule 26-2, the parties stipulate and agree

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to modify/extend the Scheduling Order (ECF No. 33) and respectfully request the

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Court approve the proposed schedule, set forth herein. This is the first stipulation for

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the extension of these deadlines. This request is submitted at least twenty-one (21)

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days or more before the close of discovery (July 18, 2024) is made in good faith, and

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is supported by good cause.

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STATEMENT OF FACTS IN SUPPORT OF STIPULATION

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On April 5, 2024, most of the Defendants answered Mr. Davis’s complaint (ECF

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32). On April 22, this Court entered a scheduling order contemplating a 90 day period

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for discovery to be completed, with an end date of July 18, 2024. ECF 33.

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Counsel for the parties have since conferred, and agree that more time is

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necessary to complete discovery.

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involving complex medical issues, with multiple claims concerning different issue,

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voluminous medical records, and which will likely involve experts. Accordingly the

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parties would propose the following schedule be adopted, running from May 3, 2024.

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

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Additional time is needed because this is a case

The parties may engage in a discovery for a period of 180 days, ending
on October 30, 2024;

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Any and all pleadings that may be brought under Fed. R. Civ. P. 13 and

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14, or joining additional parties under Fed. R. Civ. P. 19 and 20, must

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be filed within 60 days, which is July 2, 2024. Any party causing

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additional parties to be joined or brought into this action must

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contemporaneously serve a copy of this Order on the new party or

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parties.

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

Amendments to pleadings as provided for under Fed. R. Civ. P. 15, if

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they are allowed without leave of Court, or motions for leave to amend,

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must comply with LR 15-1 and must be filed and served within 90 days

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from the date of this order, which is August 1, 2024.

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Expert disclosures must be made on or before August 30, 2024, and

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disclosures of rebuttal experts must be made on or before September 30,

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2024.

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

Dispositive Motions: that they be filed and served no later than
November 29, 2024;

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Joint Pretrial Order: that it be due on December 30, 2024. If dispositive

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motions are filed, the deadline for filing the joint pretrial order will be

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suspended until 30 days after decision on the dispositive motions or

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further court order.

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CONCLUSION

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Based on the foregoing and for good cause appearing, the Parties respectfully

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request that the Court approve their Stipulation and alter the discovery deadlines as

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set forth above.

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Dated May 7, 2024

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Aaron D. Ford
Attorney General

Rene L. Valladares
Federal Public Defender

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/s/ Jessica Brown
_____________________________

/s/ Ryan Norwood

Jessica Brown
Deputy Attorney General

Ryan Norwood
Assistant Federal Public Defender

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IT

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IS SO ORDERED:

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______________________________
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE
Dated: ________________________
DATED: 5/8/2024

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