Sanchez v. Renown South Meadows Medical Center

Filing 97

ORDER GRANTING 96 Stipulation to Extend Time : Proposed Joint Pretrial Order due by 8/9/2024. Signed by Chief Judge Miranda M. Du on 6/5/2024. (Copies have been distributed pursuant to the NEF - DRM)

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1 SANDRA KETNER, ESQ. Nevada Bar No. 8527 2 3 SIMONS HALL JOHNSTON PC 690 Sierra Rose Drive 4 Reno, Nevada 89511 Telephone: (775) 785-0088 5 Fax: (775) 785-0087 Attorney for Defendant Renown Health 6 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 690 Sierra Rose Dr., Reno, NV 89511 Phone: (775) 785-0088 SIMONS HALL JOHNSTON PC 11 12 13 LUCERO SANCHEZ, Case No.: 3:21-cv-00352-MMD-CSD Plaintiff, vs. RENOWN HEALTH, a non-profit Nevada Corporation, and DOES 1-20, inclusive, 14 ORDER GRANTING STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE JOINT PRETRIAL ORDER [SECOND REQUEST] Defendant 15 16 Plaintiff Lucero Sanchez and Defendant Renown Health (collectively, the “Parties”), by and 17 through their counsel of record, hereby stipulate and agree that the deadline to file the Joint Pretrial 18 Order (“JPTO”), which is currently set for June 10, 2024, be extended for a period of sixty (60) 19 days until Friday, August 9, 2024, due to recent developments in this case described more fully 20 below. 21 The Parties and their counsel attended a settlement conference on April 10, 2024, but were 22 unable to resolve the case. Thereafter, counsel for the Parties began diligently reviewing the file to 23 confer and prepare the JPTO. While doing so, defense counsel identified a discrepancy in the 24 diaries produced by Plaintiff in this action. Defense counsel promptly notified Plaintiff’s counsel 25 of the discrepancy after the close of business on May 22, 2024. Counsel for the parties briefly 26 discussed the issue by phone the following morning and Plaintiff’s counsel filed a Motion to 27 28 Page 1 of 2 690 Sierra Rose Dr., Reno, NV 89511 Phone: (775) 785-0088 SIMONS HALL JOHNSTON PC 1 Withdraw as Counsel later that day. (ECF No. 92). A hearing regarding the Motion to Withdraw 2 as Counsel is scheduled before Magistrate Judge Denney on June 7, 2024. (ECF No. 95). 3 Plaintiff’s counsel has represented to the Court that a fundamental breakdown in the 4 attorney/client relationship has necessitated his request to withdraw as counsel in this case. 5 Plaintiff’s counsel has also denied having any knowledge that different versions of Plaintiff’s diary 6 existed. Plaintiff is expected to attend the hearing on June 7, 2024. However, her position and/or 7 explanation regarding the existence of different versions of her diary is known only to her counsel 8 at this time and protected from disclosure by the attorney-client privilege. Given the unknown 9 circumstances of how different versions of Plaintiff’s diaries were created and/or produced in this 10 case, Defendant intends to oppose the Motion to Withdraw as Counsel and move for sanctions. 11 Therefore, the results of the hearing regarding the Motion to Withdraw as Counsel are uncertain. 12 In light of these unusual developments, including the potential need for Plaintiff to secure 13 new counsel to try the case, the Parties request a 60-day extension up to and including August 9, 14 2024, by which to prepare and file the JPTO. This stipulation is made in good faith and not for 15 purposes of delay. 16 Dated: June 4, 2024 Dated: June 4, 2024 /s/ Luke Busby LUKE BUSBY, ESQ 316 California Ave., #82 Reno, NV 89509 /s/ Sandra Ketner SANDRA KETNER, ESQ. Simons Hall Johnston PC 690 Sierra Rose Drive Reno, Nevada 89511 Counsel for Defendant, Renown Health 17 18 19 20 21 Counsel for Plaintiff 22 ORDER 23 IT IS SO ORDERED. 24 June 5th Dated this _______ day of ______________ 2024. 25 26 ________________________________ U.S. District Judge 27 28 Page 2 of 2

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