Guzman v. Westlake Services, LLC et al

Filing 12

SCHEDULING ORDER granting #11 Stipulated Discovery Plan and Scheduling Order. Discovery due by 6/30/2025. Motions due by 7/29/2025. Proposed Joint Pretrial Order due by 8/28/2025. Signed by Magistrate Judge Brenda Weksler Nancy J. Koppe on 1/29/2025. (Copies have been distributed pursuant to the NEF - MAM) Modified on 1/30/2025 (LE).

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1 2 3 4 5 6 7 8 George Haines, Esq. Nevada Bar No. 9411 Gerardo Avalos, Esq. Nevada Bar No. 15171 FREEDOM LAW FIRM, LLC 8985 South Eastern Ave., Suite 100 Las Vegas, NV 89123 Phone: (702) 880-5554 FAX: (702) 385-5518 Email: info@freedomlegalteam.com Attorneys for Plaintiff Carlos Guzman 9 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 10 11 12 Carlos Guzman, 13 Case No.: 2:24-cv-02236 -GMN-NJK Discovery Plan and Scheduling Order Submitted in Compliance with LR 26-1(b) Plaintiff, 14 v. 15 16 Westlake Services, LLC and Speedy Recovery, Inc., 17 Defendants. 18 19 20 On December 31, 2024, Westlake Services, LLC appeared in this case and the 21 Court set a deadline to file a proposed discovery plan and scheduling order by 22 February 14, 2025. Accordingly, Carlos Guzman, Westlake Services, LLC and 23 24 Speedy Recovery, Inc. (collectively as the “Parties”), by and through their respective 25 counsel, hereby submit this Joint Discovery Plan and Scheduling Order. The parties 26 27 28 -1Discovery Plan and Scheduling Order 1 will require 180 days of discovery measured from the date that Westlake Services, 2 LLC filed its answer to Plaintiff's complaint. 3 DISCOVERY PLAN 4 5 6 7 8 9 10 11 12 13 14 15 The parties propose the following discovery plan and scheduling order: 1. Initial disclosures ………………... 2. Amend pleadings and add parties .. 3. Expert disclosures (initial): ……… 4. Expert disclosures (rebuttal): ……. 5. Discovery cutoff date: …………… 6. Dispositive motions: …………….. 7. Pretrial order …………………….. March 3, 2025 February 14, 2025 March 31, 2025 April 30, 2025 May 30, 2025 June 30, 2025 July 29, 2025 August 28, 2025 In the event that dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until 30 days after decision on the dispositive motions or until further order of the court. Pretrial Disclosures: The disclosures required by Rule 26(a)(3), and any 16 17 objections thereto, shall be included in the joint pretrial order. 18 Extensions or Modifications of the Discovery Plan and Scheduling Order: 19 Applications to extend any date set by the discovery plan, scheduling order, or other 20 21 22 23 order must comply with the Local Rules. Protective Order: The parties may seek to enter a stipulated protective order pursuant to Rule 26(c) prior to producing any confidential documents. 24 25 26 27 28 -2Discovery Plan and Scheduling Order 1 Electronic Service: The parties agree that pursuant to Rules 5(b)(2)(E) and 2 6(d) of the Federal Rules of Civil Procedure any pleadings or other papers may be 3 served by sending such documents by email. 4 5 Alternative Dispute Resolution Certification: The parties certify that they met 6 and conferred about the possibility of using alternative dispute-resolution processes 7 including mediation, arbitration, and early neutral evaluation. The parties have not 8 9 reached any stipulations at this stage. 10 11 Alternative Forms of Case Disposition Certification: The parties certify that they considered consent to trial by a magistrate judge under 28 U.S.C. § 636(c) and 12 13 Fed. R. Civ. P. 73 and the use of the Short Trial Program (General Order 2013-01). 14 The parties have not reached any stipulations at this stage. 15 Electronically Stored Information: The parties have discussed the retention 16 17 and production of electronic data. The parties agree that service of discovery by 18 electronic means, including sending original electronic files by email or on a cd is 19 20 sufficient. The parties reserve the right to revisit this issue if a dispute or need arises. 21 /// 22 /// 23 24 /// 25 /// 26 /// 27 28 -3Discovery Plan and Scheduling Order 1 Electronic evidence conference certification: The parties further intend to 2 present evidence in electronic format to jurors for the purposes of jury deliberations 3 at trial. The parties discussed the presentation of evidence for juror deliberations but 4 5 6 did not reach any stipulations as to the method as this early stage. Dated: January 28, 2025. 7 8 FREEDOM LAW FIRM 9 /s/ George Haines George Haines, Esq. Gerardo Avalos, Esq. 8985 South Eastern Ave., Suite 100 Las Vegas, NV 89123 Counsel for Plaintiff Carlos Guzman 10 11 12 13 14 DICKINSON WRIGHT PLLC 15 16 17 18 19 /s/ Gabriel A. Blumberg Gabriel A. Blumberg, Esq. 3883 Howard Hughes Parkway, Suite 800 Las Vegas, Nevada 89169-0965 Counsel for Westlake Services, LLC and Speedy Recovery, Inc. 20 21 22 23 24 25 26 27 28 -4Discovery Plan and Scheduling Order 1 SCHEDULING ORDER 2 The above-set stipulated Discovery Plan of the parties shall be the Scheduling Order for this action pursuant to Federal Rule of Civil Procedure 16(b) and Local Rule 16-1 , except that initial disclosures must be exchanged by February 14, 2025. 3 4 5 6 IT IS SO ORDERED: 7 ___________________________________ 8 UNITED STATES MAGISTRATE JUDGE 9 January 29, 2025 DATED: ___________________________ 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -5Discovery Plan and Scheduling Order

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