State Farm Fire and Casualty Company v. Spacom, L.L.C.

Filing 19

ORDER granting 18 Stipulation TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST). IT IS SO ORDERED that the discovery deadlines be extended as follows: Discovery due by 7/15/2025. Motions due by 8/12/2025. Proposed Joint Pretrial Order due by 11/12/2025. Signed by Magistrate Judge Brenda Weksler on 3/5/2025. (Copies have been distributed pursuant to the NEF - CAH)

1 George F. Hand, Esq.
Nevada Bar No. 8483
2 [e-mail]
Samantha A. Herbeck, Esq.
3 Nevada Bar No. 14542
[e-mail]
4 HAND & SULLIVAN, LLC
3442 North Buffalo Drive
5 Las Vegas, Nevada 89129
Telephone: [phone]
6 Facsimile: [phone]
7 Attorneys for Plaintiff
STATE FARM FIRE AND CASUALTY COMPANY as
8 Subrogee of THOR JORGENSEN
9

UNITED STATES DISTRICT COURT

10

DISTRICT OF NEVADA

11

STATE FARM FIRE AND CASUALTY
12 COMPANY as Subrogee of THOR
JORGENSEN,
13
Plaintiff,
14
vs.
15

CASE NO.: 2:24-cv-01543-CDS-BNW

STIPULATION AND ORDER TO
EXTEND DISCOVERY DEADLINES
(SECOND REQUEST)

16 SPACOM, L.L.C. dba BATCADDY LLC, a
foreign limited liability company; DOES I - v,
17 inclusive; ROE CORPORATIONS I - V,
inclusive,
18
Defendants.
19
20
21

Pursuant to LR IA6-1(a), LR IA 6-2, and LR 26-3, Plaintiff STATE FARM FIRE AND

22 CASUALTY COMPANY, as Subrogee of THOR JORGENSEN, by and through its counsel of
23 record George F. Hand, Esq. and Samantha A. Herbeck, Esq., from the law firm of HAND &
24 SULLIVAN, LLC and Defendant SPACOM, LLC., by and through its attorney of record Richard
25 Waltjen, Esq. from the law firm of PYATT SILVESTRI (collectively referred to as the “Parties”),
26 hereby stipulate and agree to extend the Discovery Deadlines in the current Discovery Plan and
27 Scheduling Order in this matter for a period of 60 days.
28 / / /

1

A.

DISCOVERY COMPLETED

2

1.

Plaintiff has made initial disclosures of witnesses and documents;

3

2.

Defendant has made initial disclosures of witnesses and documents;

4

3.

Plaintiff has made supplemental disclosures of witnesses and documents;

5

4.

Defendant has made supplemental disclosure of witnesses and documents;

6

5.

Plaintiff has made their first set of interrogatories to Defendants;

7

6.

Plaintiff has made their first set of requests for production of documents to
Defendants;

8
9

7.

Defendant has made their responses to Plaintiff’s first set of interrogatories;

10

8.

Defendant has made their responses to Plaintiff’s first set of requests for
production of documents;

11
12

9.

Defendant has made their first set of interrogatories to Plaintiff;

13

10.

Defendant has made their first set of requests for production of documents to
Plaintiff;

14
15

11.

Defendant has made their first of requests for admissions to Plaintiff;

16

12.

Defendant has made their second set of requests for production of documents
to Plaintiff;

17
13.

18

and

19
14.

20

Plaintiff has made their responses to Defendants first set of requests for
production of documents;

21
22

Plaintiff has made their responses to Defendants first set of interrogatories;

B.

DISCOVERY THAT REMAINS TO BE COMPLETED

23

1.

Plaintiffs responses to Defendants first set of requests for admissions.

24

2.

Plaintiffs responses to Defendants second set of requests for production of
documents.

25
26

3.

March 11, 2025.

27
28

The deposition of Defendant's 30(b)(6) Witness is currently scheduled for

4.

The deposition of Thor Jorgensen.
2

1

5.

The deposition of Jette Jorgensen.

2

6.

The deposition of Plaintiffs 30(b)(6) Witness.

3

7.

Additional Depositions, including expert depositions, remain to be
completed by both parties

4
5

8.

Additional Written Discovery remains to be completed by both parties.

6

9.

Initial and Rebuttal Expert disclosures remain to be completed by both
parties.

7
10.

8

Other further appropriate discovery may also be necessary.

9

C.

REASONS WHY DISCOVERY REMAINING WAS NOT COMPLETED

10

The parties have been working diligently to complete discovery; however, due to the

11 scheduling of depositions, other discovery has been delayed. Thus, although the parties have made
12 every effort to cooperate throughout the process, they nonetheless will be unable to complete
13 discovery before the current deadlines expire.
14

The proposed extension will provide the parties with the time needed to complete the

15 remaining discovery necessary for the parties’ claims and defenses.
16

This Request is not sought for any improper purpose or other purpose of delay. Rather, it is

17 sought by the parties for the purpose of conducting all necessary discovery.
18 / / /
19 / / /
20 / / /
21 / / /
22 / / /
23 / / /
24 / / /
25 / / /
26 / / /
27 / / /
28 / / /
3

1

D.

DISCOVERY DEADLINES

Current

Joint Proposed
Amended

1.

Close of Discovery

05/16/2025

07/15/2025

2.

Final Dates for Expert Disclosures

2
3
4
5
6
7
8

(a)

Initial Disclosures

03/17/2025

05/16/2025

(b)

Rebuttal Disclosures

04/15/2025

06/13/2025

3.

Dispositive Motions

06/13/2025

08/12/2025

4.

Pretrial Order

07/15/2025

11/12/2025

9
10 HAND & SULLIVAN, LLC

PYATT SILVESTRI

11 Dated: March 3, 2025

Dated: March 3, 2025

12 /s/ George F. Hand
George F. Hand, Esq. (#8483)
13 Samantha A. Herbeck, Esq. (#14542)
3442 North Buffalo Drive
14 Las Vegas, Nevada 89129
Attorneys for Plaintiff
15

/s/ Richard Waltjen
James P.C. Silvestri, Esq (#3603)
Richard Waltjen, Esq. (#13416)
7670 W. Lake Mead Blvd., Suite 250
Las Vegas, Nevada 89128
Attorneys for Defendant

16
17
18
19
20
21
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24
25
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27
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4

1

ORDER

2

Upon Stipulation of the parties;

3

IT IS SO ORDERED that the discovery deadlines be extended as follows:

4

1.

Close of Discovery

07/15/2025

5

2.

Final Dates for Expert Disclosures

6

(a)

Initial Disclosures

05/16/2025

7

(b)

Rebuttal Disclosures

06/13/2025

8

3.

Dispositive Motions

08/12/2025

9

4.

Pretrial Order

11/12/2025

10
11

5 day of _______________,
Dated this ___
2025.
March

12
13
14

____________________________________
UNITED STATES MAGISTRATE JUDGE

15 Respectfully submitted this 3rd day of March, 2025.
16 HAND & SULLIVAN, LLC
17 /s/ George F. Hand
George F. Hand, Esq.
18 Nevada Bar No. 8483
Samantha A. Herbeck, Esq.
19 Nevada Bar No. 14542
3442 N. Buffalo Drive
20 Las Vegas, Nevada 89129
Attorneys for Plaintiff
21
22
23
24
25
26
27
28
5

Juliana Cerriteno
From:
Sent:
To:
Cc:
Subject:

Richard Waltjen <[e-mail]>
Friday, February 28, 2025 7:40 AM
Juliana Cerriteno
George Hand; Samantha Herbeck; Michelle Mockbee
RE: State Farm v Spacom - 2:24-cv-01543 - H&S File No.: 5221.080

Good morning,
I reviewed the Second SAO to Extend Discovery Deadlines. You have my authorization to use my esignature.
Thanks

Richard Waltjen
Associate Attorney

7670 Lake Mead Boulevard, Suite 250
Las Vegas, Nevada 89128
Telephone: [phone]
Facsimile: [phone]
[e-mail]
www.pyattsilvestri.com
The information contained in this communication may be confidential or legally privileged and is intended only for the recipient named
above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of
this communication or its contents is strictly prohibited. If you have received this communication in error, please immediately advise the
sender and delete the original and any copies from your computer system.

From: Juliana Cerriteno <[e-mail]>
Sent: Thursday, February 27, 2025 4:31 PM
To: Richard Waltjen <[e-mail]>
Cc: George Hand <[e-mail]>; Samantha Herbeck <[e-mail]>; Michelle Mockbee
<[e-mail]>
Subject: State Farm v Spacom - 2:24-cv-01543 - H&S File No.: 5221.080
sophosp sm artbannerend

Good Afternoon Mr. Waltjen,
Attached please find draft of SAO to Extend Discovery Deadlines for your review. If you have any requested revisions
please use redlines, if none please confirm we have authority to affix your e-signature to the SAO for submission to the
court. Thank you.
Sincerely,
Juliana Cerriteno, Paralegal
Hand & Sullivan, LLC
[e-mail]
1