Opinion
2:20-cv-00559-JCM-BNW
01-03-2022
PETER J. HELLMAN, Plaintiff, v. GREYSTONE NEVADA, LLC; LENNAR SALES CORP.; DOES I-X, inclusive, and ROE CORPORATIONS XI-XX, inclusive, Defendants. GREYSTONE NEVADA, LLC; and LENNAR SALES CORP., Third-Party Plaintiffs, v. AMANDA HELLMAN, Third-Party Defendant.
GEORGE F. HAND, ESQ. HAND & SULLIVAN, LLC Attorney for Third-Party Defendant AMANDA HELLMAN John B. Greene, Esq. VANNAH & VANNAH Attorneys for Plaintiff PETER J. HELLMAN Amtoj S. Randhawa, Esq. J. Nathan Owens, Esq. NEWMEYER & DILLION LLP Attorneys for Defendant/Third-Party Plaintiffs GREYSTONE NEVADA, LLC and LENNAR SALES CORP
GEORGE F. HAND, ESQ.
HAND & SULLIVAN, LLC
Attorney for Third-Party Defendant AMANDA HELLMAN
John B. Greene, Esq.
VANNAH & VANNAH
Attorneys for Plaintiff PETER J. HELLMAN
Amtoj S. Randhawa, Esq.
J. Nathan Owens, Esq.
NEWMEYER & DILLION LLP
Attorneys for Defendant/Third-Party Plaintiffs GREYSTONE NEVADA, LLC and LENNAR SALES CORP
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES
[FIFTH REQUEST]
BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE
Third-Party Defendant AMANDA HELLMAN, by and through her attorney of record, George F. Hand, Esq. of HAND & SULLIVAN, LLC, Plaintiff PETER J. HELLMAN, by and through his attorney of record, John B. Greene, Esq. of VANNAH & VANNAH, and Defendant/Third-Party Plaintiffs GREYSTONE NEVADA, LLC and LENNAR SALES CORP., by and through their attorneys of record, Amtoj S. Randhawa, Esq. and J. Nathan Owens, Esq. of NEWMEYER & DILLION LLP, hereby stipulate pursuant to LR IA 6-1, and request the Court to extend all remaining discovery deadlines by 60 days, as set forth herein.
This is the fifth stipulation for the extension of time for discovery. Good cause exists for the requested extension given that Third-Party Defendant AMANDA HELLMAN recently appeared in this action on July 28, 2021, only five months ago. Considering the complex nature of this case, Mrs. HELLMAN needs additional time to depose witnesses and propound written discovery in order to effectively defend herself against the claims asserted by Defendants/Third-Party Plaintiffs GREYSTONE NEVADA, LLC (“Greystone”) and LENNAR SALES CORP. (“Lennar”).
The parties have been working diligently to continue to conduct discovery and believe it judicious to extend the discovery deadlines to allow AMANDA HELLMAN to properly conduct discovery subsequent to her appearance in this case. Therefore, the Parties respectfully request a 60-day extension of all current discovery deadlines.
As of the date of this Stipulation, the parties have completed the following discovery:
a. All parties have exchanged initial disclosures per FRCP 26(a);
b. Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its First Set of Special Interrogatories and Requests for Production of Documents and Plaintiff Peter Hellman served Responses to same;
c. Plaintiff Peter Hellman served Supplemental Responses to Defendant/Third-Party Plaintiff Lennar's First Set of Requests for Production;
d. Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Lennar with its First Set of Requests for Admission, Requests for Production, and Interrogatories and Defendant Lennar served Responses to same;
e. Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Greystone with its First Set of Interrogatories, Requests for Admission, and Requests for Production and Defendant Greystone served Responses to same;
f. Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its Second Set of Requests for Production of Documents and Special Interrogatories and Plaintiff Peter Hellman responded to same;
g. Plaintiff Peter Hellman served Defendant/Third-Party Plaintiff Lennar with its Second Set of Requests for Production and Defendant Lennar served Responses to same;
h. Defendant/Third-Party Plaintiff Lennar served Third-Party Defendant Amanda Hellman with its First Set of Requests for Production of Documents and Special Interrogatories and Third-Party Defendant Amanda Hellman served Responses to same;
i. Third-Party Defendant Amanda Hellman made a Demand for Prior Pleadings and Discovery to Defendants/Third-Party Plaintiffs Lennar and Greystone and Defendants/Third-Party Plaintiffs Lennar and Greystone served a Response to same;
j. Defendant/Third-Party Plaintiff Lennar served Third-Party Defendant Amanda Hellman with its Second Set of Requests for Production of Documents and Third-Party Defendant Amanda Hellman served Responses to same;
k. Defendant/Third-Party Plaintiff Lennar served Plaintiff Peter Hellman with its Third Set of Requests for Production of Documents and Plaintiff Peter Hellman served Responses to same;
l. Third-Party Defendant Amanda Hellman served Third-Party Plaintiffs Lennar and Greystone with its First Set of Requests for Production of Documents and Interrogatories and Third-Party Plaintiffs Lennar and Greystone served Responses to same;
m. Defendant/Third-Party Plaintiff Lennar served Supplemental Responses to Plaintiff Peter Hellman's Second Set of Requests for Production of Documents;
n. Defendant/Third-Party Plaintiff Greystone served Plaintiff Peter Hellman with its First Set of Requests for Production of Documents and Interrogatories and Plaintiff Peter Hellman served Responses to same;
o. Third-Party Defendant Amanda Hellman and Defendants/Third-Party Plaintiffs Lennar and Greystone met and conferred regarding various discovery issues;
p. Third-Party Defendant Amanda Hellman served Third-Party Plaintiffs Lennar and Greystone with its First Set of Supplemental Interrogatories;
q. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the deposition of Plaintiff Peter Hellman;
r. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the deposition of Lars Bangen;
s. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the deposition of Third-Party Defendant Amanda Hellman;
t. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the deposition of Dr. Kimberly Adams;
u. Plaintiff Peter Hellman has completed the deposition of Thomas Dome individually and as the FRCP 30(b)(6) witness for Defendant/Third-Party Plaintiff Greystone;
v. Plaintiff Peter Hellman has completed the deposition of Melissa Flores individually and as the FRCP 30(b)(6) witness for Defendant/Third-Party Plaintiff Lennar;
w. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the Independent Medical Evaluation (“IME”) of Plaintiff Peter Hellman;
x. Defendants/Third-Party Plaintiffs Lennar and Greystone have completed the deposition of Dr. Jessica Knirk;
y. Defendants/Third-Party Plaintiffs Lennar and Greystone served their Initial Expert Disclosures;
z. Plaintiff Peter Hellman served his Initial Expert Disclosures; and
aa. Defendants/Third-Party Plaintiffs Lennar and Greystone served their Rebuttal Expert Disclosures.
In light of the circumstances set forth above, the parties hereby stipulate and request to continue the dates set forth by the Court as follows:
CURRENT DISCOVERY DEADLINES
Current
Joint Proposed Amended
1. Close of Discovery
01/06/2022
03/07/2022
2. Final Date to File Motions to Amend Pleadings or Add Parties
10/08/2021
No Change
3. Final Dates for Expert Disclosures
(a) Initial Disclosures
11/07/2021
No Change
(b) Rebuttal Disclosures
12/07/2021
No Change
4. Dispositive Motions
02/05/2022
04/06/2022
5. Joint Pretrial Order
03/07/2022
05/06/2022
ORDER
Upon Stipulation of the parties;
IT IS HEREBY ORDERED that the discovery deadlines be extended as follows:
1. Close of Discovery
03/07/2022
2. Final Date to File Motions to Amend Pleadings or Add Parties
10/08/2021
3. Final Dates for Expert Disclosures
(a) Initial Disclosures
11/07/2021
(b) Rebuttal Disclosures
12/07/2021
4. Dispositive Motions
04/06/2022
5. Joint Pretrial Order
05/06/2022
ORDER
IT IS SO ORDERED.
Dated: December 29, 2021
George F. Hand, Esq.
HAND & SULLIVAN, LLC
Attorneys for Third-Party Defendant AMANDA HELLMAN
John B. Greene, Esq.
VANNAH & VANNAH
Attorneys for Plaintiff PETER J. HELLMAN
Amtoj S. Randhawa, Esq.
J. Nathan Owens, Esq.
NEWMEYER & DILLION LLP
Attorneys for Defendant/Third-Party Plaintiffs GREYSTONE NEVADA, LLC and LENNAR SALES CORP