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)

1 SANDRA KETNER, ESQ.
Nevada Bar No. 8527
2 [e-mail]
3 SIMONS HALL JOHNSTON PC
690 Sierra Rose Drive
4 Reno, Nevada 89511
Telephone: [phone]
5 Fax: [phone]
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: [phone]

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: [phone]

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