Opinion
2:22-cv-00583-JAD-NJK
01-31-2023
BARBARA MORIN, an individual, Plaintiff, v. MICHAEL WILLIAMSON, an individual; FIRSTFLEET, INC., a foreign corporation; DOE INDIVIDUALS 1-X, inclusive; and ROE CORPORATIONS 1-X, inclusive, Defendants.
THE POWELL LAW FIRM BAUMAN LOEWE WITT & MAXWELL PAUL D. POWELL, ESQ. MICHAEL C. MILLS, ESQ. RYAN T. O'MALLEY, ESQ.
THE POWELL LAW FIRM
BAUMAN LOEWE WITT & MAXWELL
PAUL D. POWELL, ESQ.
MICHAEL C. MILLS, ESQ.
RYAN T. O'MALLEY, ESQ.
ORDER TO MODIFY THE DISCOVERY PLAN AND SCHEDULING ORDER TO EXTEND DISCOVERY PLAN DEADLINES (THIRD REQUEST)
Plaintiff Barbara Morin and Defendants FirstFleet, Inc. and Michael Williamson, by and through their respective counsel, and pursuant to Local Rule 26-4, and via this Second Request stipulate to modify their discovery plan as follows:
1. Plaintiff filed her Complaint on February 22, 2022 in the Eighth Judicial District Court, Clark County, Nevada.
2. Defendants answered on March 28, 2022.
3. Defendants removed the matter to this court on April 6, 2022.
4. Counsel for the parties conducted a Fed.R.Civ.P. 26(f) conference on April 28, 2022. The parties submitted their Joint Discovery Plan and Scheduling Order to the Court on May 5, 2022. The Court denied the parties' request for Special Scheduling Review. [ECF 7]
5. The parties prepared and filed a Stipulation and Order to Modify the Discovery Plan and Scheduling Order (Second Request) on July 19, 2022 The Court granted the Stipulation and Order. [ECF 21], Discovery Cut-Off: 11/28/2022
Last Day to Amend Pleadings: 08/29/2022
Expert Disclosure Deadline: 09/26/2022
Rebuttal Expert Disclosure: 10/28/2022
Dispositive Motions Deadline: 12/27/2022
Pre-Trial Order: 01/30/2023
The second amended discovery plan was approved by United States Magistrate Judge Nancy J. Koppe on 07/20/2022.
6. In compliance with Local Rule 26-4, the parties provide the following information regarding the discovery status:
(a) Discovery Completed pursuant to Fed.R.Civ.P. 26(a): Defendants:
Defendants' Initial Disclosures 05/11/2022
Defendants' Requests for Production of Document 05/03/2022
Defendants' Interrogatories 05/03/2022
Defendants' Order submitted to medical providers via authorization provided by Plaintiffs attorney 05/17/2022
Defendants' First supplement Disclosures 06/07/2022
Defendants' Second Supplement Disclosures 06/15/2022
Defendants' Third Supplement Disclosures 06/23/2 022
Defendants' Fourth Supplement Disclosures 07/12/2022
Defendants' First Supplement Requests for
Production of Documents 07/18/2022
Defendants' Fifth Supplement Disclosures 08/05/2022
Defendants' Sixth Supplement Disclosures 09/02/2022
Defendants' Seventh Supplement Disclosures 09/13/2022
Defendants' Eighth Supplement Disclosures 09/19/2022
Defendants' Ninth Supplement Disclosures 09/26/2022
Defendants' Tenth Supplement Disclosures 10/07/2022
Defendants' Eleventh Supplement Disclosures 10/27/2022
Defendants' Twelfth Supplement Disclosures 11/09/2022
Defendants' Thirteenth Supplement Disclosures 11/21/2022
Defendants' Fourteenth Supplement Disclosures 11/28/2022
Defendants' Fifteenth Supplement Disclosures 01/04/2023
Defendants' Sixteenth Supplement Disclosures 01/13/2023
Defendants' Seventeenth Supplement Disclosures 01/27/2023
Plaintiffs:
Plaintiff's Initial Disclosures 05/19/2022
Plaintiff's First Supplement Disclosures 05/31/2022
Plaintiff Responded to Requests for Production of Documents 06/10/2022
Plaintiff Answered Interrogatories' 06/10/2022
Plaintiffs Second Supplement Disclosures 06/17/2022
Plaintiff attended her Independent Medical Examination 07/08/2022
Plaintiff's Third Supplement Disclosures 08/22/2022
Plaintiff First Supplemental Responses to Requests for
Production of Documents 08/23/2 022
Plaintiff First Supplemental Answers to Interrogatories 08/29/2022
Plaintiff's Fourth Supplement Disclosures 09/23/2022
Plaintiff's Fifth Supplement Disclosures 11/02/2022
Plaintiff's Sixth Supplement Disclosures 11/07/2022
Plaintiff's Seventh Supplement Disclosures 11/18/2022
Plaintiff's Eighth Supplement Disclosures 11/28/2022
Plaintiff's Ninth Supplement Disclosures 12/21/2022
Plaintiff's Tenth Supplement Disclosures 01/23/2023
Plaintiff's Eleventh Supplement Disclosures 01/27/2023
(b) Discovery that remains to be completed:
None.
(c) Reasons why discovery was not completed:
The parties participated in a private mediation on January 24, 2023. The parties are still considering the mediator's proposal.
(d) Proposed Schedule:
The parties propose a 30 day extension to submit the Pre-Trial Order. The parties recently mediated this case but were unsuccessful in resolving the matter. The parties did not want to spend the time preparing this order if the matter was going to settle. Now that there is no settlement, the parties are intent of preparing for trial. The proposed extended dates will be:
Discovery Cut-Off: CLOSED
Last Day to Amend Pleadings: CLOSED
Expert Disclosure Deadline: CLOSED
Rebuttal Expert Disclosure: CLOSED
Dispositive Motions Deadline: CLOSED
Pre-Trial Order: 03/01/2023
(If dispositive motions are filed, the deadline for the filing of the joint pre-trial order will be suspended until 30 days after decision on the dispositive motions or further court order.)
CONCLUSION
For the foregoing reasons, the parties herein respectfully request this Honorable Court to modify the Discovery Plan and Scheduling Order to extend all discovery deadlines.
Approved as to form and content:
ORDER
IT IS SO ORDERED.