Opinion
2:22-cv-00169-APG-BNW
02-13-2023
Manichanh Sitivong, Plaintiff, v. United States of America; DOES I through X, inclusive; ROE BUSINESS ENTITIES, I through X, inclusive, Defendants.
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar Number 7709 SKYLER H. PEARSON Assistant United States Attorneys for the United States DENNIS M. PRINCE Nevada Bar No. 5092 ANDREW R. BROWN Nevada Bar No. 15785 PRINCE LAW GROUP 10801 W. Charleston Blvd., Suite 560 Las Vegas, Nevada 89135 And- CHAD M. GOLIGHTLY LAW OFFICE OF CHAD M. GOLIGHTLY, LTD. ANDREW R. BROWN Attorneys for Plaintiff
JASON M. FRIERSON United States Attorney District of Nevada Nevada Bar Number 7709 SKYLER H. PEARSON Assistant United States Attorneys for the United States
DENNIS M. PRINCE Nevada Bar No. 5092 ANDREW R. BROWN Nevada Bar No. 15785 PRINCE LAW GROUP 10801 W. Charleston Blvd., Suite 560 Las Vegas, Nevada 89135 And- CHAD M. GOLIGHTLY LAW OFFICE OF CHAD M. GOLIGHTLY, LTD. ANDREW R. BROWN Attorneys for Plaintiff
STIPULATION AND ORDER TO AMEND DISCOVERY PLAN AND EXTEND DEADLINES
(THIRD REQUEST)
Pursuant to Local Rules IA 6-1 and 26-4, Plaintiff, Manichanh Sitivong, and Defendant, United States of America, through counsel, submit the following Stipulation to Extend Deadlines 30 days. This is the third request for an extension of case deadlines. This stipulation is being submitted 15 days prior to the next discovery deadline.
A. Discovery Completed:
1. The parties have exchanged Rule 26(a) disclosures and supplemented their disclosures.
2. Defendant continues to send out subpoenas and receive medical records from Plaintiff's medical providers.
3. Plaintiff' was deposed on August 25, 2022.
4. Special Agent Jae Carlton Beasley was deposed on October 18, 2022.
5. Plaintiff served written discovery on October 17, 2022.
6. Plaintiff took the investigating officer's deposition on November 18, 2022.
7. The parties have designated experts and served initial expert reports.
B. Discovery Remaining:
1. The parties may serve additional written discovery, third-party subpoenas, and plan to conduct depositions of Plaintiff's treating medical providers and others.
2. The parties will continue to supplement their initial disclosures.
3. In addition, the parties will designate and depose retained and non-retained medical experts, if applicable.
4. Depositions of designated experts.
5. Continued production of additional medical records and billing.
C. Need for Extension of Discovery Plan:
The current 30-day extension is being sought to allow the parties sufficient time to schedule and conduct the depositions of the parties' respective experts. Due to scheduling conflicts of various experts, the parties will be unable to schedule and conduct the depositions within the current discovery plan and scheduling order. Therefore, an extension will provide the parties the necessary time to complete discovery in this case.
Respective counsel for the parties have a good working relationship and have discussed this request and are in agreement that an additional 30-days is appropriate. This additional time will also allow the parties sufficient time to continue to conduct discovery.
D. Proposed New Discovery Schedule:
1. Discovery Cutoff Dated: Discovery cutoff is currently scheduled for March 31, 2023, and will be extended to April 30, 2023.
2. Expert Disclosures: Rebuttal expert disclosures currently due March 3, 2023, will be extended to April 3, 2023.
3. Dispositive Motions: Dispositive motions currently due May 1, 2023, will be extended to May 30, 2023, which is the first weekday 30 days after discovery cutoff.
4. Pre-Trial Order: A Joint Pretrial Order shall be filed by June 29, 2023, which is 30 days after the deadline for filing dispositive motions. However, if any dispositive motions are filed, the Joint Pretrial Order shall be due 30 days after decision on such motion(s). Disclosures under Fed.R.Civ.P. 26(a)(3) and any objections thereto shall be included in the Joint Pretrial Order.
IT IS SO ORDERED.