Opinion
2:23-cv-00488-CDS-EJY
10-19-2023
BRANDON ROCHE, Plaintiff, v. DIEGO GUZMAN, and TSG FLEET SERVICES, LLC, a California Limited Liability Company; DOES I - X, and ROE CORPORATIONS XI - XX, inclusive, Defendants.
Schuetze, McGaha Turner & Ferris, PLLC William W. McGaha, Esq. Attorneys for Plaintiff Fabian Vancott Trevor R. Waite, Esq. Attorneys for Defendants
Schuetze, McGaha Turner & Ferris, PLLC William W. McGaha, Esq. Attorneys for Plaintiff
Fabian Vancott Trevor R. Waite, Esq. Attorneys for Defendants
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)
IT IS HEREBY STIPULATED, by and between the parties through their undersigned counsel of record, WILLIAM W. McGAHA, ESQ., of SCHUETZE, McGAHA, TURNER & FERRIS, PLLC, counsel for Plaintiff, and TREVOR R. WAITE, ESQ., of FABIAN VANCOTT, counsel for Defendants, as follows:
The parties stipulated and respectfully request that this Honorable Court extend the discovery deadlines, and all deadlines arising therefrom, found in their Discovery Plan and Scheduling Order, originally filed July 17, 2023, in this matter as set forth below:
A. Discovery Cut-Off:
a. Current Deadline: March 26, 2024
b. New Deadline: April 26, 2024
B. Initial Expert Disclosures & Reports:
a. Current Deadline: January 26, 2024
b. New Deadline: February 26, 2024
C. Rebuttal Expert Disclosures & Reports:
a. Current Deadline: February 26, 2024
b. New Deadline: March 26, 2024
D. Motion to Amend Pleadings & Add Parties:
a. Current Deadline: December 27, 2023
b. New Deadline: January 26, 2024
E. Interim Status Report:
a. Current Deadline: March 16, 2023
b. New Deadline: June 16, 2023
F. Dispositive Motions:
a. Current Deadline: April 25, 2024
b. New Deadline: May 27, 2024
G. Pre-Trial Order:
a. Current Deadline: May 27, 2024
b. New Deadline: June 27, 2024
The parties to this action are not making this request for the purpose of unduly delaying the trial in this matter. The parties are diligently working together to complete discovery and the additional time will help provide time for meaningful ADR as there are complicated insurance and unusual insurance coverage issues. Additionally, Plaintiff BRANDON ROCHE is claiming extensive injuries arising from the subject collision, requiring reports from multiple medical experts, as well as depositions of both parties and said experts. Defendants are located in California.
To date, parties have served written discovery and disclosures. The Defendant has responded to written discovery and Plaintiff is drafting response to written discovery.
Defendant Diego Guzman was deposed on September 21, 2023. Plaintiff's deposition needs to be taken as well as the Person Most Knowledgeable for Defendant TSG Fleet Services, LLC.
After all depositions have been completed and the transcripts and/or reports received, additional discovery may be pursued to explore and/or clarify any issues that arose during the same.
Therefore, the parties require additional time to complete the full extent of discovery. They therefore stipulate to extend the discovery deadlines, and all deadlines arising therefrom, as set forth above.
ORDER
IT IS SO ORDERED.