Opinion
2:22-cv-01774-JAD-BNW
07-19-2023
MIROSLAV KEFURT, derivatively on behalf of BREMACH, INC., a Nevada corporation, Plaintiff, v. BREMACH, INC., a Nevada corporation. Nominal Defendant v. REINIER "RAY" HOOGENRAAD, an individual, BENJAMIN "BEN" MONTGOMERY, an individual, Defendants.
Leah Martin, Esq. Kevin Hejmanowski, Esq. Nevada Bar No. 10612 LEAH MARTIN LAW Attorneys for Plaintiff Benjamin Montgomergy c/o O,HARA & GRECO Defendant in Pro Se Reinier Hoogenraad Defendant In Pro Se
Leah Martin, Esq. Kevin Hejmanowski, Esq. Nevada Bar No. 10612 LEAH MARTIN LAW Attorneys for Plaintiff
Benjamin Montgomergy c/o O,HARA & GRECO Defendant in Pro Se
Reinier Hoogenraad Defendant In Pro Se
FIRST STIPULATION AND ORDER TO CONTINUE DISCOVERY DEADLINES AND TRIAL
BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE
Plaintiff MIROSLAV KEFURT ("Plaintiff'), by and through his counsel Leah Martin Law, REINIER "RAY" HOOGENRAAD ("Defendant RH"), and BENJAMIN "BEN" MONTGOMERY ("Defendant BM") (together the "Defendants") (collectively the "Parties"), hereby stipulate and agree to extend the discovery deadlines ninety days and trial as set forth herein. This is the first stipulation for extension of discovery.
I. DISCOVERY COMPLETED
1. The Plaintiff has submitted initial documents and witnesses;
2. Plaintiff propounded his first set of written discovery on Defendant RH;
II. DISCOVERY THAT REMAINS TO BE COMPLETED
3. Plaintiff to serve its first set of written discovery on Defendant BM;
4. Defendants to submit their initial documents and witnesses;
5. Depositions of the Parties, experts and third-party witnesses;
6. Disclosure of expert witnesses;
7. Disclosure of rebuttal expert witnesses;
8. Any additional supplemental written discovery that may be needed;
9. Any other discovery which may be determined as relevant and necessary by the Parties.
III. REASONS WHY DISCOVERY WAS NOT COMPLETED WITHIN THE CURRENT DEADLINES
The Plaintiff has been actively participating in discovery but requires additional time to complete discovery. The Defendants are exploring retention of counsel. This stipulation is not submitted for any improper purpose or to unnecessarily delay the proceedings. The Parties submit that good cause exists to grant the stipulated ninety-day extension of the discovery deadlines and trial for the following reasons: Defendant RH has not completed disclosures or filed any responses to Plaintiff s written discovery. Defendant BM has not filed an answer to Plaintiffs complaint, disclosures, and Plaintiff has not had an opportunity to conduct discovery relating to Defendant BM. Finally, Defendants are pro se and special care must be taken.
IV. PROPOSED EXTENDED DEADLINES
Deadline
Current Deadline
Proposed
Amend Pleadings/Add Parties
May 3, 2023
Aug 1, 2023
Initial Experts
Jun 5, 2023
Sep 3, 2023
Designation of Rebuttal Experts
Jul 6, 2023
Oct 4, 2023
Close of Discovery
Aug 3, 2023
Nov 1, 2023
Dispositive Motions
Sep 4, 2023
Dec 3, 2023
Joint Pre-Trial Order
Oct 5, 2023
Jan 3, 2024
V. THIS EXTENSION WILL AFFECT THE TRIAL DATE
The requested extension would affect the trial date. The Parties respectfully request that the trial date be rescheduled to the Court's next available trial date.
VI. CONCLUSION
Based upon the foregoing, the Parties respectfully request and submit that good cause exists, and for the Court to adopt the forgoing deadlines and reschedule trial in this case.
ORDER
IT IS SO ORDERED