Opinion
2:20-cv-01814-CDS-DJA
11-23-2022
Pamela Brown, Individually, and as Special Administratrix of the Estate of James Brown, Plaintiffs, v. United States of America, Defendant.
LAIRD LAW, PLLC JASON M. FRIERSON DANIAL LAIRD TROY K. FLAKE
LAIRD LAW, PLLC
JASON M. FRIERSON
DANIAL LAIRD
TROY K. FLAKE
STIPULATION TO EXTEND REMAINING DEADLINES (SIXTH REQUEST)
Pursuant to Local Rule 26-4 and Local Rule IA 6-1, the parties respectfully request a 60-day extension of the remaining deadlines. This is the sixth request for an extension of time.
A. Discovery completed to date
This is a complex medical malpractice wrongful death case. The parties have provided disclosures, exchanged written discovery, including numerous medical records, and subpoenaed multiple third parties. The parties have deposed the plaintiff, other family members of the decedent, and three of the medical providers who treated the decedent. The deadlines for amendment and to add parties have passed. The parties have closely cooperated to move discovery forward.
B. Remaining Discovery
The parties have completed fact witness depositions and written discovery. The main task remaining in discovery is conducting the expert witness deposition of Plaintiff's expert, Dr. MacGregor.
C. Reasons for Requested Extension
Plaintiff's expert, Dr. MacGregor has a demanding schedule and limited availability. The parties cooperated to find mutually agreeable dates for his deposition and scheduled it for November 4, 2022. Unfortunately, counsel for the United States' father passed away on October 28, 2022, and he was required to cancel the deposition to attend the funeral. Dr. MacGregor and Plaintiff's counsel have been accommodating, but the parties have been unable to find another date for the deposition within the discovery period.
Given the approaching holidays and various scheduling conflicts, the parties respectfully request an additional 60 days to complete Dr. MacGregor's deposition. They are seeking this extension in good faith and without purpose of delay.
D. Proposed revised discovery schedule
Current due date
Proposed due date
Discovery Cut-Off
November 22, 2022
January 23, 2023
Dispositive Motions
December 27, 2022
February 27, 2023
Pre-Trial Order
January 23, 2022
March 20, 2023
IT IS SO ORDERED.