Afsharalmanchi v. Otis Elevator Company

Filing 19

ORDER granting 18 Stipulation to Extend Discovery Deadlines. Discovery due by 10/22/2025. Motions due by 11/21/2025. Proposed Joint Pretrial Order due by 12/22/2025. Signed by Magistrate Judge Elayna J. Youchah on 3/11/2025. (Copies have been distributed pursuant to the NEF - MAM)

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REBECCA L. MASTRANGELO, ESQ.
Nevada Bar No. 5417
ROGERS, MASTRANGELO, CARVALHO & MITCHELL
700 S. Third Street
Las Vegas, NV 89101
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Su-Lyn Combs (pro hac vice)
TUCKER ELLIS LLP
515 South Flower Street
Forty-Second Floor
Los Angeles, CA 90071
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
TUCKER ELLIS LLP
V. SATHIENMARS SBN 282619
[e-mail]
201 Mission Street
Suite 2310
San Francisco, CA 94105-1839
Telephone: [phone]
Facsimile: 415.617.2409
Attorneys for Defendant
OTIS ELEVATOR COMPANY

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MANSOUR AFSHARALMANCHI, an
individual,
Plaintiff,
v.

EJY
CASE NO.: 2:24-cv-02178-JAD-NJK
STIPULATION AND ORDER TO
EXTEND DISCOVERY PLAN AND
SCHEDULING ORDER
(First Request)

OTIS ELEVATOR COMPANY; a Foreign
Corporation; DOES I through X; and ROE
CORPORATIONS I through X, inclusive;
Defendants.

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STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)

1703536.1

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TUCKER ELLIS LLP

Cleveland ? Columbus ? Denver ? Los Angeles ? San Francisco

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COMES NOW, Plaintiff MANSOUR AFSHARALMANCHI, by and through his attorneys
of record, the law firm HEIDARI LAW GROUP and Defendant OTIS ELEVATOR COMPANY
by and through its counsel of record, the law firms ROGERS, MASTRANGELO, CARVALHO,
AND MITCHELL and TUCKER ELLIS LLP, and hereby request the discovery deadlines in the
previously filed Order [Doc 11] be extended by ninety (90) days, pursuant to FRCP 29 and LR 26.4,
as follows:
A.
•

The parties have conducted a FRCP 26(f) conference;

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The parties have served their respective FRCP 26(a) disclosures;

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Defendant has served upon Plaintiff one set of Requests for Production and one set of
Interrogatories. Plaintiff has responded.;

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Plaintiff provided provider specific authorizations;

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Defendant served a Subpoena Duces Tecum on Venetian Las Vegas Gaming, LLC and
obtained documents, photographs, and video surveillance.

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B.

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DISCOVERY COMPLETED TO DATE

DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF
DISCOVERY

Discovery to be completed includes:
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Obtain Plaintiff’s relevant medical provider records from numerous medical providers;

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Coordinate and schedule a site inspection of the Subject Elevator;

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Defendant needs to depose Plaintiff;

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Defendant needs to depose other occupants in the elevator at the time of the Subject
Incident;

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Defendant need to conduct expert discovery on Plaintiff, inclusive of, e.g., Rule 35
examination(s);

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Depositions of numerous expert witnesses and rebuttal expert witnesses;

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Depositions of Plaintiff’s treating physicians; and

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Additional written discovery and depositions as necessary.

The parties agree, pursuant to Local Rule 6-1, that good cause exists for the requested extension.

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STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)
1703536.1

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TUCKER ELLIS LLP

Cleveland ? Columbus ? Denver ? Los Angeles ? San Francisco

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Plaintiff Mansour Afsharalmanchi alleges serious injuries and other related damages as a result of
an alleged elevator drop on August 3, 2022 at The Venetian Hotel. There were 15 other hotel
employees in the elevator with him. On May 20, 2024, Alma Vargas, one of thee passengers on the
elevator with Plaintiff, filed a Complaint in the Eighth Judicial District Court for Clark County
alleging identical causes of action against Defendant. Otis filed a Notice of Removal for Alma
Vargas; however the case was remanded for lack of subject matter jurisdiction. (See, 2:24-cv-01148
[Doc 12]. The parties have been working diligently to complete discovery in this matter, along with
the Vargas matter, but there is some overlap in the discovery for both cases. Specifically, due to
logistical challenges in scheduling depositions of fact witnesses and a site inspection in both cases,
additional time is required. A brief extension in the current discovery plan would assist in ensuring
a comprehensive and equitable discovery process.
C.

PROPOSED PLAN FOR COMPLETING DISCOVERY

Event

Current Deadline

Proposed Deadline

Amending the Pleadings and

March 26, 2025

June 24, 2025

Initial Expert Disclosure

April 27, 2025

August 25, 2025

Rebuttal Expert Disclosures

May 27, 2025

September 25, 2025

Discovery Cut-Off Date

June 24, 2025

October 22, 2025

Dispositive Motions

July 24, 2025

November 21, 2025

Joint Pre-Trial Order, if No

August 25, 2025

December 22, 2025

Adding Parties

Dispositive Motions

D.

THE CURRENT TRIAL DATE
This matter has not been scheduled for trial.

E.

NUMBER OF REQUESTS FOR EXTENSION
This is the first request to extend discovery deadlines.

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STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)
1703536.1

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Dated this 11th day of March, 2025

Dated this 11th day of March, 2025

HEIDARI LAW GROUP, PLLC

ROGERS, MASTRANGELO, CARVALHO
& MITCHELL

/s/ Sam Ryan Heidari
SAM RYAN HEIDARI, ESQ.
Nevada Bar No. 13347
611 South 6th Street
Las Vegas, NV 89101
Attorneys for Plaintiff

/s/ Rebecca L. Mastrangelo
REBECCA L. MASTRANGELO, ESQ.
Nevada Bar No. 5417
700 South 3rd Street
Las Vegas, NV 89101
Attorneys for Defendant Otis Elevator
Company

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TUCKER ELLIS LLP

Cleveland ? Columbus ? Denver ? Los Angeles ? San Francisco

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Dated this 11th of March, 2025

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TUCKER ELLIS LLP

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/s/ Su-Lyn Combs
SU-LYN COMBS, ESQ. (Pro Hac Vice)
515 South Flower Street
Forty-Second Floor
Los Angeles, CA 90071
Attorneys for Defendant Otis Elevator
Company
IT IS SO ORDERED

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United States Magistrate Judge

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March 11, 2025
DATED: __________________________

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STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (First Request)
1703536.1