Clark et al v. Sun Country Holdings, Inc.

Filing 36

ORDER Granting 35 Stipulation for Extension of Time for Parties to Serve Disclosure of Experts and Expert Reports. It is hereby ORDERED that Parties shall serve their disclosures of initial expert witnesses and initial expert reports on or befo re August 23, 2024, and Parties shall serve their disclosures of rebuttal expert witnesses and rebuttal expert reports on or before September 20, 2024. See order for other deadline details. Signed by Magistrate Judge Brenda Weksler on 6/4/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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DANIEL A. MANN, 15594
MARK A. DOMBROFF (PHV Admitted)
JAMES A. EASTWOOD (PHV Admitted)
FOX ROTHSCHILD LLP
One Summerlin
1980 Festival Plaza Dr., Suite 700
Las Vegas, Nevada 89135
And
2020 K Street, N.W.
Suite 500
Washington, DC 20006
Telephone:
702.699.5936
202.461.3100
Fax No.:
702.597.5503
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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JOHN EDWARD CLARK, individually,
ANGELIQUA CHENEE GROCE,
individually, and DANNESHA
KIRKWOOD,
individually,
Plaintiff,

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vs.

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SUN COUNTRY HOLDINGS, INC., a
foreign corporation; DOE INDIVIDUALS I
through X, inclusive; and ROE ENTITIES I
through X, inclusive,
Defendants.

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Case No. 2:24-cv-00379-CDS-BNW
STIPULATION TO EXTEND TIME
FOR PARTIES TO SERVE
DISCLOSURE OF EXPERTS AND
EXPERT REPORTS
Current deadline: June 24, 2024, for
Initial Expert and July 22, 2024, for
Rebuttal Expert
New deadline: August 23, 2024, for Initial
Expert and September 20, 2024, for
Rebuttal Expert

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Plaintiffs, JOHN EDWARD CLARK, individually, ANGELIQUA CHENEE GROCE,
individually, and DANNESHA KIRKWOOD, individually (“Plaintiffs”), by and through their

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counsel of record, MICHAEL L. SHIRTS, ESQ., of DIMOPOULOS INJURY LAW; Defendant
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SUN COUNTRY AIRLINES HOLDINGS, INC. (“Sun Country”), by and through its counsel,

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159320773.1

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DANIEL A. MANN, ESQ., MARK A. DOMBROFF, ESQ., and JAMES A. EASTWOOD,

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ESQ., of FOX ROTHSCHILD LLP, hereby stipulate to extend the deadline for Parties to serve
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their disclosure of experts and expert reports for a period of sixty (60) days, up to and
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including August 23, 2024.
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1.

On April 4, 2024, the Court issued an Order setting the discovery schedule.

2.

Per the Court’s Order, the deadline for Parties to serve disclosure of experts and

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expert reports was by June 24, 2024.
3.

The parties are looking to mediate this matter and require this deadline to be

extended to provide amble time to schedule a date to avoid unnecessary litigation costs before
mediation.

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4.

Accordingly, the Parties agree and stipulate to extend the deadline for Parties to

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serve their disclosure of experts and expert reports for a period of sixty (60) days, up to and

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including August 23, 2024.

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5.

This deadline extension would require the deadline for rebuttal expert disclosures

to be extended as well to avoid the deadline to be before the initial disclosures of expert witnesses.
6.

Accordingly, the Parties agree and stipulate to extend the deadline for Parties to

serve their disclosure of rebuttal experts and expert reports for a period of sixty (60) days,
September 20, 2024, which is 29 days after disclosure of experts since the typical 30 days falls
on a Saturday.

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8.

The Parties respectfully request that the Court enter an Order consistent with the

Parties’ Stipulation as detailed herein.

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159320773.1

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DATED this 3rd day of June, 2024
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FOX ROTHSCHILD LLP
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/s/ Daniel A. Mann
DANIEL A. MANN, 15594
MARK A. DOMBROFF (PHV Admitted)
JAMES A. EASTWOOD (PHV Admitted)
FOX ROTHSCHILD LLP
One Summerlin
1980 Festival Plaza Dr., Suite 700
Las Vegas, Nevada 89135
And
2020 K Street, N.W.
Suite 500
Washington, DC 20006
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants

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DIMOPOULOS INJURY LAW
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/s/ Michael L. Shirts
MICHAEL L. SHIRTS, ESQ.
Nevada Bar No. 10223
6671 South Las Vegas Boulevard, Suite 275
Las Vegas, Nevada 89119
[e-mail]
Attorney for Plaintiffs

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159320773.1

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DANIEL A. MANN, 15594
MARK A. DOMBROFF (PHV Admitted)
JAMES A. EASTWOOD (PHV Admitted)
FOX ROTHSCHILD LLP
One Summerlin
1980 Festival Plaza Dr., Suite 700
Las Vegas, Nevada 89135
And
2020 K Street, N.W.
Suite 500
Washington, DC 20006
Telephone:
702.699.5936
202.461.3100
Fax No.:
702.597.5503
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOHN EDWARD CLARK, individually,
ANGELIQUA CHENEE GROCE,
individually, and DANNESHA
KIRKWOOD,
individually,
Plaintiff,

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vs.

Case No. 2:24-cv-00379-CDS-BNW
[PROPOSED] ORDER ON
STIPULATION TO EXTEND TIME FOR
PARTIES TO SERVE DISCLOSURE OF
EXPERTS AND EXPERT REPORTS

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SUN COUNTRY HOLDINGS, INC., a
foreign corporation; DOE INDIVIDUALS I
through X, inclusive; and ROE ENTITIES I
through X, inclusive,
Defendants.

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Current deadline: June 24, 2024, for Initial
Expert and July 22, 2024, for Rebuttal
Expert
New deadline: August 23, 2024, for Initial
Expert and September 20, 2024, for
Rebuttal Expert

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The Court, having considered the Parties’ Stipulation to Extend Time for Parties to Serve
Disclosures of Experts and Export Rpeorts, and good cause appearing, hereby ORDERS that

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Parties shall serve their disclosures of initial expert witnesses and initial expert reports on or

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before August 23, 2024, and Parties shall serve their disclosures of rebuttal expert witnesses

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and rebuttal expert reports on or before September 20, 2024.

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IT IS SO ORDERED.

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Dated this __
4 day of June, 2024.

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By _________________________________
Hon. Brenda Weksler
Magistrate Judge

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