Opinion
Civil No.: 2:11-CV-01788-GEB-KJN
01-13-2012
ROSA AYALA, NATALIA MADRIGAL, FABIAN MADRIGAL, STEVE and KIMBERLEE HEINRICH, Plaintiffs, v. SILVER LEGACY HOTEL and RESORTS, KONE INC., Defendants.
Eduardo A. Gonzalez, Attorneys for Plaintiffs ROSA AYALA, NATALIA MADRIGAL, FABIAN MADRIGAL, STEVE HEINRICH and KIMBERLEE HEINRICH DANNER & CHONOLES, L.L.P. Michael J. Danner, Attorneys for Defendants KONE INC. AND ELDORADO JOINT VENTURE
Michael J. Danner (SBN 79269)
DANNER & CHONOLES, L.L.P.
Attorneys for Defendants, KONE INC. AND THE CIRCUS AND ELDORADO
JOINT VENTURE, A NEVADA GENERAL PARTNERSHIP
DBA THE SILVER LEGACY RESORT CASINO RENO
ERRONEOUSLY SUED AS SILVER LEGACY HOTEL AND RESORTS
STIPULATION AND [PROPOSED] ORDER FOR MODIFICATION OF STATUS (PRETRIAL SCHEDULING)
ORDER TO EXTEND DEADLINE FOR EXPERT DISCLOSURES
COMES NOW Plaintiffs ROSA AYALA, NATALIA MADRIGAL, FABIAN MADRIGAL, STEVE and KIMBERLEE HEINRICH, by and through their attorney of record, Eduardo A. Gonzalez of David Allen & Associates and Defendants, KONE INC. and THE CIRCUS AND ELDORADO JOINT VENTURE, by and through their attorney, Michael J. Danner of Danner & Chonoles, L.L.P., (collectively all referred to herein as the "Parties") and hereby stipulate as follows:
Whereas, pursuant to the Court's Pretrial Scheduling order, the deadline for initial expert witness disclosures pursuant to Federal Rule of Civil Procedure 26 (a) (2) (B) and (C) has been set for April 19, 2012 and the deadline for contradictory and/or rebuttal expert disclosures authorized under Rule 26 (a) (2) (D) (ii) has been set for May 18, 2012 and the
Parties agree that additional time is necessary to conduct discovery and identify appropriate expert witnesses.
THEREFORE, the Parties now stipulate to continue the deadline for initial expert witness disclosures from April 19, 2012 to June 19, 2012 and to continue the deadline for contradictory and/or rebuttal expert disclosures from May 18, 201 to July 18, 2012. The Parties respectfully request that these deadlines be ordered extended by the Court accordingly.
DAVID ALLEN & ASSOCIATES
By: _________
Eduardo A. Gonzalez, Attorneys for
Plaintiffs ROSA AYALA, NATALIA
MADRIGAL, FABIAN MADRIGAL, STEVE
HEINRICH and KIMBERLEE HEINRICH
DANNER & CHONOLES, L.L.P.
By: _________
Michael J. Danner, Attorneys for
Defendants KONE INC. and THE CIRCUS
AND ELDORADO JOINT VENTURE
order
Pursuant to the Stipulation of the Parties hereto, the Pretrial Scheduling Order is modified as follows on page 3, lines 9 - 13:
"Each party shall comply with Federal Rule of Civil Procedure 26(a)(2)(B) and (C)'s initial expert witness disclosure requirements on or before June 19, 2012, and any contradictory and/or rebuttal expert disclosures authorized under Rule 26(a)(2)(d)(ii) on or before July 18, 2012."
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GARLAND E. BURRELL, JR.
United States District Judge