Martin v. BJ's Restaurant Operations Company

Filing 12

ORDER Granting 11 Stipulation for Extension of Time. Discovery due by 9/14/2024. Motions due by 10/15/2024. Proposed Joint Pretrial Order due by 11/15/2024. Signed by Magistrate Judge Daniel J. Albregts on 7/3/2024. (Copies have been distributed pursuant to the NEF - AMMi)

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1 2 3 4 5 6 BETSY C. JEFFERIS-AGUILAR, ESQ. Nevada Bar No. 12980 HICKS & BRASIER, PLLC 2630 S. Jones Blvd. Las Vegas, Nevada 89146 Phone: (702) 628-9888 Fax: (702) 960-4118 E-Mail: baguilar@lvattorneys.com Attorney for Plaintiff 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 RHONDA CORA MARTIN, an individual, Plaintiff, vs. BJ’S RESTAURANT OPERATIONS COMPANY, a domestic corporation; DOE EMPLOYEES OF BJ’S RESTAUANT BREWHOUSE, DOES 1-20; and ROE BUSINESS ENTITIES 1-20. inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:23-cv-01848-JAD-DJA STIPULATION TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (FIRST REQUEST) The parties stipulate to extend the remaining deadlines in the Stipulated Discovery Plan and Scheduling Order by 60 days. This is the first request to extend the Stipulated Discovery Plan and Scheduling Order. This extension is requested to allow Plaintiff’s counsel to take the deposition of Defendant’s FRCP 30(b)(6) Witness. This extension will give the parties time to 25 meet and confer regarding the topics and schedule the deposition. Defendant’s counsel would 26 also like to take the deposition of Plaintiff’s expert Dr. Bady however, he is not available until 27 August 20, 2024. Due to the 4th of July holiday and summer schedules Defendant’s FRCP 28 1 30(b)(6) Witness’s availability are limited as there may be multiple representatives assigned for 2 certain topics. 3 I. Discovery Completed 4 The parties have exchanged written discovery in the form of interrogatories and requests for 5 6 7 8 production of documents. The parties have taken depositions of the Plaintiff . Defendant has received records and imaging from all providers. The parties have exchanged expert disclosures and rebuttal expert disclosures. II. Discovery Remaining 9 10 11 Plaintiff needs to take the deposition of Defendant’s FRCP 30(b)(6) Witness and Defendant will be taking the deposition of Plaintiff’s expert witness Dr. Bady on August 20, 2024. III. Why Discovery Has Not Been Completed 12 Following the parties’ exchange of rebuttal expert disclosures, the parties are working 13 14 together to meet and confer as to the availability for Plaintiff to depose Defendant’s FRCP 15 30(b)(6) Witness as well as the topics contained in Plaintiff’s Notice. Defendant will also be 16 noticing the deposition of Plaintiff’s Expert Dr. Bady, however, he is not available until August 17 20, 2024. Due to summer schedules, including the 4th of July holiday, the parties and 18 Defendant’s representatives are understandably busier than usual. Additionally, multiple 19 representatives may be required to appear for the topics and as such, the parties need to 20 schedule the deposition for the availability of these individuals once the topics have been 21 confirmed. 22 // 23 24 // 25 26 27 28 // // 1 IV. Proposed Deadlines 2 Close of Discovery: September 14, 2024 (from July 16, 2024) 3 Dispositive Motion Deadline: October 15, 2024 (from August 16, 2024) 4 Joint Pre-Trial Order: November 15, 2024 (from September 16, 2024) 5 DATED THIS 3rd day of July 2024. 6 /s/ Betsy C. Jefferis-Aguilar_______ BETSY C. JEFFERIS-AGUILAR, ESQ. Attorneys for Plaintiff 7 8 9 DATED 3rd day of July 2024. 10 BACKUS | BURDEN /s/ Jacquelyn Franco, Esq. _______ Jack P. Burden, Esq. Jacquelyn Franco, Esq. Attorneys for Defendant BJ’S Restaurant Operations Company dba BJ’s Restaurant 11 12 13 14 15 HICKS & BRASIER, PLLC IT IS SO ORDERED. 16 17 18 19 20 21 22 23 24 25 26 27 28 __________________________________ United States Magistrate Judge 7/3/2024 Dated:_____________________________

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