Opinion
2:22-cv-00079-GMN-BNW
08-23-2022
Michael Kind, Esq. Nevada Bar No.: 13903 KIND LAW Attorney for Plaintiff Ralph Stovall
Michael Kind, Esq.
Nevada Bar No.: 13903
KIND LAW
Attorney for Plaintiff Ralph Stovall
STIPULATION TO EXTEND DISCOVERY DEADLINES
(SECOND REQUEST)
BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE
Ralph Stovall and American Honda Finance Corporation (“Honda” and jointly as the “parties”), by and through their respective counsel, hereby stipulate to modify the Court's Discovery Plan and Scheduling Order as follows:
1. Expert disclosures: from Aug 23, 2022, to Oct 22, 2022;
2. Rebuttal disclosures: from Sep 22, 2022, to Nov 21, 2022;
3. Discovery cutoff Dated: from Oct 24, 2022, to Dec 23, 2022;
4. Dispositive motions: from Nov 23, 2022, to Jan 22, 2023;
5. Pretrial order from Dec 23, 2022, to Feb 21, 2023.
Pursuant to LR 26-4, good cause exists to amend the Scheduling Order. The Parties have diligently pursued discovery. The Parties propounded written discovery on each other and Plaintiff has noticed Defendant's Rule 30(b)(6) deposition. Plaintiff intends to disclose an expert but needs additional time to obtain written discovery responses and take Defendant's deposition before an expert can be properly disclosed.
Honda is the only remaining active defendant in this case since all other defendants have already settled or been dismissed. ECF Nos. 25, 31.
Plaintiff initially noticed Honda's deposition for June 15, 2022. The parties still need additional time to take the depositions.
Further good cause exists to amend the Scheduling Order to provide additional time to complete settlement discussions, which are actively ongoing.
Pursuant to LR 26-4(a), Plaintiff propounded and Honda responded to written discovery requests. Plaintiff is working together with Honda to re-schedule Honda's depositions.
Pursuant to LR 26-4(b), the parties request additional time to take depositions and disclose experts.
Pursuant to LR 26-4(c), the reason the remaining discovery was not complete within the time limits set by the discovery plan is because expert discovery and the taking of depositions are a significant expense but settlement discussions were ongoing and the parties hoped to resolve the case prior to incurring these additional expenses.
Pursuant to LR 26-4(d), the parties' proposed discovery schedule is listed above.
This is the parties' second request for an extension of these deadlines.
ORDER
IT IS SO ORDERED