Jak Logistics, Inc. v. Stevens Transport, Inc.

Filing 26

ORDER Granting 25 Stipulation Extending Discovery Deadlines. Discovery due by 6/30/2025. Motions by 7/30/2025. Proposed Joint Pretrial Order by 8/29/2025. Signed by Magistrate Judge Maximiliano D. Couvillier, III on 3/10/2025. (Copies have been distributed pursuant to the NEF - JG)

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MICHAEL C. HETEY, ESQ.
Nevada Bar No. 5668
THORNDAL ARMSTRONG, PC
600 S. Las Vegas Boulevard, Suite 400
Las Vegas, Nevada 89101
Tel.: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendant,
STEVENS TRANSPORT, INC.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JAK LOGISTICS, INC., a Nevada corporation,

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Plaintiff,

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vs.

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STEVENS TRANSPORT, INC., a Texas
corporation,

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STIPULATION AND ORDER
EXTENDING DISCOVERY
DEADLINES (First Request)

Defendant.

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CASE NO. 2:24-cv-00413-APG-MDC

Pursuant to Local Rule 26-1, the parties respectfully request an extension of remaining
deadlines. This is the first request for an extension of time, recognizing the prior issues with the
original discovery plan and scheduling issues that resulted in the current deadlines.

This

stipulation is filed more than 21 days before the close of discovery.
I.

SUMMARY OF CASE
This case arises out of a motor vehicle accident that occurred on January 18, 2023, in

Hesperia, California. The Complaint in this matter was filed in the United States District Court,
District of Nevada on February 29, 2024 [ECF No. 1]. Defendant filed its Answer to Plaintiff’s
Complaint on May 3, 2024 [ECF No. 8]. Except for Plaintiff’s bad faith claim, liability is not in
dispute with respect to the underlying auto accident. The Parties are primarily contesting damage
issues.
The parties have been participating in discovery including multiple productions of
documents, and production of an initial expert report by Defendant and a rebuttal expert report
by Plaintiff per the current expert disclosure deadlines. However, an issue has arisen with
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JAK Logistics, Inc. v. Stevens Transport, Inc., Case No. 2:24-cv-00413-APG-MDC
Stipulation and Order to Extend Discovery Deadlines (First Request)

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respect to Defendant’s expert, Kevin Parker with Custard Insurance Adjuster, Inc. (“Custard”),

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which may require Defendant to retain a new expert to replace Mr. Parker. The Parties are also

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working to schedule private mediation. As such, the Parties have agreed that it is in their best

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interest to extend the remaining deadlines by 90-days.

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II.

DISCOVERY COMPLETED
A.

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Plaintiff

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To date, Plaintiff has conducted the following discovery:

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September 24, 2024, Initial FRCP 26 Disclosure.

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February 20, 2025, First Supplemental FRCP 26 Disclosure.

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February 20, 2025, Second Supplemental FRCP 26 Disclosure.

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February 26, 2025, Plaintiff Rebuttal Expert Disclosure.
B.

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Defendant
To date, Defendant has conducted the following discovery:

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August 23, 2024, Initial FRCP 26 Disclosure.

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January 28, 2025, Initial Expert Disclosure.

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January 28, 2025, First Supplemental FRCP 26 Disclosure.

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III.

DISCOVERY THAT REMAINS TO BE COMPLETED

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Deposition of Plaintiff’s FRCP 30(b)(6) witness.

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Deposition of Defendant’s FRCP 30(b)(6) witness.

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Depositions of potential additional fact witnesses regarding vehicle repair issues with

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non-parties Ryder Transportation Services, Inc. and Velocity.

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Deposition of Plaintiff’s expert witness.

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Deposition of Defendant’s expert witness.

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Potential written discovery.

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IV.

REASONS WHY PARTIES ARE REQUESTING EXTENSION
The Plaintiff and Defendant seek additional time to allow Defendant to resolve issues

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with Custard, participate in mediation, and complete discovery.

Based upon these

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circumstances, the parties seek a 90-day extension in good faith and not for purpose of delay.
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JAK Logistics, Inc. v. Stevens Transport, Inc., Case No. 2:24-cv-00413-APG-MDC
Stipulation and Order to Extend Discovery Deadlines (First Request)

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Below is a proposal for extensions of remaining discovery deadlines based on the current request

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to extend the discovery cutoff and pre-trial deadlines by 90 days.

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V.

PROPOSED REVISED SCHEDULE

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CURRENT DEADLINE

PROPOSED DEADLINE

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Initial Expert Designation

February 28, 2025

Closed

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Rebuttal Expert Designation

January 27, 2025

Closed

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Discovery Cut-Off

March 31, 2025

June 30, 2025

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Dispositive Motions

April 30, 2025

July 30, 2025

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Joint Proposed Pre-Trial Order

May 30, 2025

August 29, 2025

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*or 30 days after resolution of

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Dispositive Motions

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Dated this 7th day of March 2025.

Dated this 7th day of March 2025.

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LAW OFFICE OF MITCHELL STIPP, PC

THORNDAL ARMSTRONG, PC

/s/ Mitchell Stipp
Mitchell Stipp, Esq.
Nevada Bar No. 7531
1180 N. Town Center Drive, Suite 100
Las Vegas, Nevada 89144
Attorney for Plaintiff,
JAK LOGISTICS, INC.

/s/ Michael C. Hetey
Michael C. Hetey, Esq.
Nevada Bar No. 5668
600 S. Las Vegas Boulevard, Suite 400
Las Vegas, Nevada 89101
Attorneys for Defendants,
STEVENS TRANSPORT, INC.

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ORDER
IT IS SO ORDERED.
3-10-25

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UNITED STATES MAGISTRATE JUDGE

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JAK Logistics, Inc. v. Stevens Transport, Inc., Case No. 2:24-cv-00413-APG-MDC
Stipulation and Order to Extend Discovery Deadlines (First Request)