Opinion
2:22-CV-01545-JCM-DJA
07-11-2023
D. ANTHONY WASHINGTON, Plaintiffs v. PEDRO VALLADARES HIDALGO and PBRB LOGISTICS, LLC; DOES I-X, and ROE CORPORATIONS XI-XX, inclusive, Defendants.
WILLIAM W. McGAHA, ESQ. Nevada Bar #3234 SCHUETZE, McGAHA, TURNER & FERRIS PLLC Attorneys for Plaintiff WINNER & BOOZE BRUCE W. KELLEY, ESQ. Nevada Bar #7331 STEVEN D. BROKA, ESQ. Nevada Bar #15510 Attorneys for Defendants
WILLIAM W. McGAHA, ESQ.
Nevada Bar #3234
SCHUETZE, McGAHA, TURNER & FERRIS PLLC
Attorneys for Plaintiff
WINNER & BOOZE
BRUCE W. KELLEY, ESQ.
Nevada Bar #7331
STEVEN D. BROKA, ESQ.
Nevada Bar #15510
Attorneys for Defendants
STIPULATION AND ORDER TO EXTEND REBUTTAL EXPERT DISCLOSURE AND DISCOVERY DEADLINES (SECOND 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 STEVEN BROKA, ESQ., of WINNER & BOOZE counsel for Defendants, as follows:
The parties stipulated and respectfully request that this Honorable Court extend the rebuttal expert disclosure deadline and related all deadlines arising therefrom, found in their Discovery Plan and Scheduling Order, originally filed September 29, 2022, in this matter as set forth below:
A. Discovery Cut-Off:
a. Current Deadline: August 14, 2023
b. New Deadline: September 13, 2023
B. Initial Expert Disclosures & Reports:
a. Current Deadline: Closed
b. New Deadline: Closed
C. Rebuttal Expert Disclosures & Reports:
a. Current Deadline: July 17, 2023
b. New Deadline: August 16, 2023
D. Motion to Amend Pleadings & Add Parties:
a. Current Deadline: Closed
b. New Deadline: Closed
E. Interim Status Report:
a. Current Deadline: None
b. New Deadline: N/A
F. Dispositive Motions:
a. Current Deadline: September 12, 2023
b. New Deadline: October 12, 2023
G. Pre-Trial Order:
a. Current Deadline: October 11, 2023
b. New Deadline: November 10, 2023
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. While initial expert reports were produced, rebuttal experts and reports will require more than 30 days and therefore the need to extend the rebuttal disclosure date.
To date, parties have served multiple sets of written discovery and disclosures. The parties have also responded to written discovery. Defendant Pedro Valladares Hidalgo was deposed or November 28, 2022. The depositions of Plaintiff Anthony Washington and LVMPD Officer Jeffrey Bengel were taken on December 15, 2022 and November 2, 2022, respectively. The depositions of Mark B. Kabins, M.D. and Sudhir Khemka, M.D. have been scheduled for July 29. 2023, and July 31, 2023, respectively. An Independent Medical Examination of Plaintiff was completed on November 29, 2022. The IME Report was completed on December 28, 2022. A deposition of Dr. James Forage, who conducted said IME, is scheduled for August 10, 2023. The parties therefore stipulate to extend the rebuttal disclosure deadline, and all deadlines arising therefrom, as set forth above.
ORDER
IT IS SO ORDERED.