Opinion
2:19-CV-01452-KJD-BNW
01-05-2022
DARLENE ISAAC; and HAROLD ROLAND HOWMAN, JR., Plaintiffs, v. NICOLAS FORCILLO, an individual, WERNER ENTERPRISES, INC., a foreign corporation, DOES I through X, inclusive; and/or ROE CORPORATIONS I through X, inclusive Defendants.
MICHAEL C. HETEY, ESQ. Nevada Bar No. 5668 HARRY J. ROSENTHAL, ESQ. Nevada Bar No. 10208 THORNDAL ARMSTRONG DELK BALKENBUSH & EISINGER Attorneys for Defendants, WERNER ENTERPRISES, INC. and NICOLAS FORCILLO H&P LAW THORNDAL ARMSTRONG DELK MARJORIE L. HAUF, ESQ. MICHAEL C. HETEY, ESQ. MATTHEW G. PFAU, ESQ. HARRY J. ROSENTHAL, ESQ. Attorneys for Plaintiffs, DARLENE ISAAC and HAROLD ROLAND HOWMAN, JR. Attorneys for Defendants, WERNER ENTERPRISES, INC. and NICOLAS FORCILLO
MICHAEL C. HETEY, ESQ.
Nevada Bar No. 5668
HARRY J. ROSENTHAL, ESQ.
Nevada Bar No. 10208
THORNDAL ARMSTRONG DELK
BALKENBUSH & EISINGER
Attorneys for Defendants, WERNER ENTERPRISES, INC. and NICOLAS FORCILLO
H&P LAW
THORNDAL ARMSTRONG DELK
MARJORIE L. HAUF, ESQ.
MICHAEL C. HETEY, ESQ.
MATTHEW G. PFAU, ESQ.
HARRY J. ROSENTHAL, ESQ.
Attorneys for Plaintiffs, DARLENE ISAAC and HAROLD ROLAND HOWMAN, JR.
Attorneys for Defendants, WERNER ENTERPRISES, INC. and NICOLAS FORCILLO
STIPULATION AND ORDER TO CONTINUE THE JOINT PRETRIAL ORDER DEADLINE
(First Request)
The parties respectfully request the Court's permission to continue the Joint Pretrial Order deadline currently set for January 5, 2022.
I. BACKGROUND
The Joint Pretrial Order deadline of January 5, 2022 was set by Court Order [Doc. No. 67]. The Court has not yet set trial or a pre-mediation settlement conference in this matter.
The parties respectfully request a one (1) week continuance of the deadline in order to complete the Joint Pretrial Order from January 5, 2022 to January 12, 2022.
This request is being made due to the Christmas and New Year holidays; as well as, defense counsel preparing for a trial that was set for January 3, 2022 (Sines v Valley Health and Allied Universal, No. A-19-787286-C, Dept. XXII) and having to be on the East Coast in New York the second half of December due to family issues and illness (undersigned Defense counsel's parents). Plaintiff counsel, Matthew Pfau, Esq. was also preparing for trial in the matter of Gray v. Fogg, which began on January 3, 2022, and is currently in trial. Further, this case involves two Plaintiffs who treated in multiple differing states leading to substantial medical records, which in turn is leading to a potentially large No. of exhibits and documents within exhibits, and the parties require additional time to attempt to work on objections and or stipulations due to the volume of case data.
In addition, the parties are working on coordinating three proposed trial dates and at this point would not have a trial date earlier than April 25, 2022 such that a one-week extension would impact a trial setting with this Court.
Counsel for the parties are attempting to agree upon three agreeable trial dates and at present the earliest potential trial date may be late April 2022, and more likely a later month in 2022, therefore, the undersigned counsel submit that the one week extension requested herein should not impact other pre-trial requirements. . . . . . . . . . . . . . . . . . . . . . . . .
II. CONCLUSION
The parties submit this Stipulation to continue the deadline for filing the Joint Pretrial Order from January 5, 2022 to January 12, 2022 in good faith and not to delay this litigated proceeding; and, ask this Honorable Court to grant this Stipulation.
ORDER
IT IS SO ORDERED.