Opinion
2:19-cv-00874-GMN-EJY
08-25-2022
LAURA PETERS, Plaintiff, v. SWIFT TRANSPORTATION CO. OF ARIZONA, LLC; DOE DRIVER; DOES I through XX, inclusive; and ROE BUSINESS ENTITIES I through XX, inclusive, Defendants.
D.Lee Roberts, Jr., Esq. Ryan T. Gormley, Esq. WEINBERG,WHEELER, HUDGINS, GUNN & DIAL, LLC Attorneys for Defendant Swift Transportation Co. of Arizona, LLC Ramzy Paul Ladah, Esq. LADAH LAW FIRM, PLLC Attorneys for Plaintiff Laura Peters
D.Lee Roberts, Jr., Esq.
Ryan T. Gormley, Esq.
WEINBERG,WHEELER, HUDGINS,
GUNN & DIAL, LLC
Attorneys for Defendant Swift Transportation Co. of Arizona, LLC
Ramzy Paul Ladah, Esq.
LADAH LAW FIRM, PLLC
Attorneys for Plaintiff Laura Peters
STIPULATION AND ORDER TO EXTEND DISPOSITIVE MOTION DEADLINE
(FIRST REQUEST)
GLORIA M. NAVARRO, DISTRICT JUDGE UNITED STATES DISTRICT COURT.
Defendant Swift Transportation Co. of Arizona, LLC (“Swift”) and Plaintiff Laura Peters (“Ms. Peters” or “Plaintiff'), by and through their respective undersigned counsel, hereby stipulate and agree to extend the current dispositive motion deadline set forth in the Scheduling Order entered on June 16, 2022 (ECF No. 72) pursuant to LR 26-3. This is the first stipulation to specifically extend the dispositive motion deadline.
A. Statement Specifying the Discovery Completed
The parties have substantially completed all discovery in this matter, including disclosing thousands of pages of records, serving and responding to Rule 34 vehicle inspection requests, three medical examinations of Ms. Peters arranged by Swift, expert disclosures, and dozens of depositions of lay witnesses, treating providers, and expert witnesses.
B. Specific Description of the Discovery that Remains to be Completed
The parties have agreed to allow Swift to take three additional depositions of Valerie Tucker, Bonnie Clear, and a follow-up deposition of Plaintiff. The parties will also supplement discovery as permitted by law.
C. Reasons Why Additional Time is Needed for the Dispositive Motion Deadline
The current dispositive motion deadline is August 29, 2022. The parties submit that good cause exists to extend this deadline by three weeks to allow the follow-up deposition of Plaintiff to take place prior to the deadline (the depositions had to be rescheduled through the mutual agreement of the parties given Covid-19 concerns for counsel, among other significant scheduling concerns, including trial) and to allow the parties to engage in further good-faith discussions in an effort to negate the need for a dispositive motion on certain issues, if not entirely.
D. Proposed Schedule
Event
Current Deadline (ECF No. 72)
Proposed Deadline
Discovery Cutoff
Passed
Passed
Deadline Amend Pleadings/Add Parties
Passed
Passed
Initial Expert Disclosure
Passed
Passed
Rebuttal Expert Disclosure
Passed
Passed
Dispositive Motions
08/29/2022
09/19/2022
Pretrial Order
30 days after the dispositive motion deadline unless dispositive motions are pending, in which case, the deadline would be 60 days after the order on the dispositive motion(s) is issued.
Same
If dispositive motions are filed, the deadline for filing the pretrial order will be suspended until 30 days after decision on the dipositive motions or further court order. The disclosures required by Fed.R.Civ.P. 26(a)(3) and any objections to them must be included in the pretrial order.
IT IS SO ORDERED.