Jaragosky v. Ford Motor Company, No. 2:2017cv02089 - Document 31 (D. Nev. 2018)
Court Description: ORDER Granting 30 Second Stipulation to Extend Discovery Dates. Discovery due by 11/27/2018. Motions due by 12/28/2018. Proposed Joint Pretrial Order due by 1/18/2019. Signed by Magistrate Judge George Foley, Jr on 3/30/2018. (Copies have been distributed pursuant to the NEF - SLD)
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Jaragosky v. Ford Motor Company Doc. 31 Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 1 of 6 1 2 3 4 Joshua D. Cools Nevada Bar No. 11941 SNELL & WILMER L.L.P. 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, NV 89169 Telephone: (702) 784-5200 Facsimile: (702) 784-5252 Email: jcools@swlaw.com 5 6 Attorneys for Defendant FORD MOTOR COMPANY 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 RONALD R. JARAGOSKY, a single man, L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Snell & Wilmer 11 Plaintiff, STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE DATES (SECOND REQUEST) 12 vs. 13 FORD MOTOR COMPANY, a Delaware corporation; and JOHN DOE ENTITIES I-X, inclusive, 14 Case No. 2:17-CV-02089-RFB-GWF 15 Defendants. 16 Plaintiff Ronald R. Jaragosky and Defendant Ford Motor Company, hereby stipulate and 17 18 agree to continue discovery in this matter by approximately 60 days. 19 I. 20 BACKGROUND 21 This is a complicated product liability action arising from a motor vehicle collision 22 involving a 2001 Ford Explorer and a 2012 Chrysler van. On December 20, 2015, Plaintiff 23 Ronald Jaragosky was riding in the front passenger seat of the 2001 Ford Explorer. The Explorer 24 was driven by non-party Judy Ann Jiworsky northbound on SR-160 in Pahrump, Nevada. As the 25 Explorer approached the intersection of SR-160 and Matthew Lane, the 2012 Chrysler van turned 26 left in front of the Explorer. The right front of the Explorer collided with right front of the 27 Chrysler van. Mr. Jaragosky sustained significant injuries in the crash. 28 /// Dockets.Justia.com L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Snell & Wilmer Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 2 of 6 1 On August 1, 2017 Plaintiff filed suit against Ford. Plaintiff alleges claims of negligence 2 and strict product liability and seeks punitive damages. Plaintiff alleges that the 2001 Ford 3 Explorer failed to adequately protect Plaintiff when the airbags did not deploy. Ford denies that 4 the 2001 Ford Explorer was defective or that they are liable for Plaintiff’s injuries and damages. 5 II. 6 REASON FOR DISCOVERY REQUEST 7 The parties have diligently pursued discovery in this case. As previously reported to the 8 Court, they had some initial difficulty obtaining the most recent medical records for Plaintiff from 9 the California facilities where Plaintiff is currently residing. Plaintiff is essentially a quadriplegic 10 and requires assistance in most of his activities of daily living. An administrator for Plaintiff’s 11 current facility was preventing Plaintiff from executing medical records authorizations which 12 delayed the requesting of his most recent medical records. Plaintiff had to subpoena these 13 records. The parties have now had the opportunity to get most of these documents. 14 Additionally, after reviewing Ford’s production of responsive documents to Plaintiff’s 15 written discovery requests, Plaintiff has identified additional documents that he needs prior to 16 expert disclosures. Ford is working on locating and producing those additional documents, but 17 will not be able to do so before the current deadline for Plaintiff’s initial expert disclosures. The 18 parties only recently determined that these documents would not be able to be produced prior to 19 the expert disclosure deadlines. For this reason, the parties agree that it will be best to extend all 20 discovery deadlines by 60 days to allow for the remaining written discovery to be completed prior 21 to expert discovery in this case. The parties represent that good cause exists for this extension 22 and that extending the expert deadline within the 21 day period set by LR 26-4 is due to 23 excusable neglect, as set forth herein. 24 III. 25 DISCOVERY STATUS 26 27 28 The following discovery has been completed: October 10, 2017 - Plaintiff’s Initial Disclosure Statement November 10, 2017 - Ford Motor Company’s Initial Disclosure Statement -2- Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 3 of 6 1 2 3 4 5 6 7 8 9 10 L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Snell & Wilmer 11 12 13 14 15 16 17 18 19 January 12, 2018 - Plaintiff’s First Set of Non-Uniform Interrogatories to Defendant Ford Motor Company January 12, 2018 - Plaintiff’s First Set of Requests to Produce to Defendant Ford Motor Company January 26, 2018 - Ford Motor Company’s First Request for Production of Documents to Ronald R. Jaragosky January 26, 2018 - Ford Motor Company’s First Set of Non-Uniform Interrogatories to Ronald R. Jaragosky January 31, 2018 - Submission of Protective Order March 12, 2018 - Deposition of Plaintiff Ronald Jaragosky March 12, 2018 - Deposition of Darby Jaragosky March 12, 2018 - Plaintiff’s Second Set of Requests to Produce to Defendant Ford Motor Company (response pending) March 14, 2018 - Deposition of Donald Patrick (non-party driver of 2012 Chrysler) March 15, 2018 - Deposition of Kevin Clickner, Pahrump Valley Fire and Rescue March 15, 2018 - Deposition of Judy Ann Jiworsky (non-party driver of 2001 Ford Explorer) March 19, 2018 - Vehicle inspection by Ford’s experts. March 22, 2018 - Deposition of Officer Truscello, Nevada Highway Patrol 20 IV. 21 DISCOVERY THAT REMAINS TO BE COMPLETED 22 A. Plaintiff: 23 1. 24 representatives; 25 2. Plaintiff will be identifying experts on both liability and damages; 26 3. Plaintiff may propound additional written discovery as needed; 27 4. Plaintiff will be deposing Defendant’s experts once disclosed. 28 Plaintiff intends to notice the 30(b)(6) depositions of Defendant’s corporate /// -3- Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 4 of 6 1 B. 2 1. 3 damages. 4 2. 5 subject vehicle on April 1, 2018. 6 3. Defendant intends to perform an additional vehicle inspection of the Defendant may propound additional written discovery as needed. V. 8 PROPOSED SCHEDULE FOR COMPLETING DISCOVERY 10 L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Defendant intends to depose Plaintiff’s experts on both liability and 7 9 Snell & Wilmer Defendant: The parties have agreed to extend all the discovery deadlines in this case by 60 days as set forth below: 11 1. Last day to amend pleadings and add parties: June 1, 2018 12 2. File the interim status report: June 1, 2018 13 3. Plaintiff’s initial expert disclosure: June 1, 2018 14 4. Defendant’s initial expert disclosure: July 30, 2018 15 5. Rebuttal expert disclosure: August 31, 2018 16 6. Discovery cut off: November 27, 2018 17 7. Dispositive motions: December 28, 2018 18 8. Joint pretrial order: January 18, 2019 19 In the event dispositive motions are filed, the date for filing the joint pretrial order shall be 20 suspended until 30 days after a decision of the dispositive motions. 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// -4- Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 5 of 6 1 VI. 2 CONCLUSION 3 Good cause is exists to extend the discovery deadlines as the parties have worked 4 diligently towards completing fact discovery prior to expert disclosure. Therefore, the parties 5 respectfully ask that this Court grant their request to adjust the case management deadlines as set 6 forth herein. 7 DATED this 29th day of March, 2018. DATED this 29th day of March, 2018. 8 SNELL & WILMER L.L.P. LAW OFFICES OF LYNN SHUMWAY 9 10 L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Snell & Wilmer 11 By: /s/ Joshua D. Cools Joshua D. Cools Nevada Bar No. 11941 3883 Howard Hughes Pkwy., Ste. 1100 Las Vegas, NV 89169 By: /s/ G. Lynn Shumway G. Lynn Shumway Arizona Bar No. 011714 4647 N. 32nd Street, Suite 230 Phoenix, AZ 85018 12 13 Attorneys for Defendant FORD MOTOR COMPANY Cory M. Jones Nevada Bar No. 5028 JONES WILSON, LLP 1522 W. Warm Springs Road Henderson, NV 89014 14 15 Brent Ghelfi (pro hac vice pending) Arizona Bar No. 011491 GHELFI LAW GROUP, PLLC 4742 North 24th Street, Suite 300 Phoenix, AZ 85016 16 17 18 Attorneys for Plaintiff RONALD R. JARAGOSKY 19 20 21 22 23 24 25 26 27 28 -5- Case 2:17-cv-02089-RFB-GWF Document 30 Filed 03/29/18 Page 6 of 6 1 Ronald R. Jaragosky vs. Ford Motor Company Case No. 2:17-CV-02089-RFB-GWF 2 ORDER 3 L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 Snell & Wilmer 4 IT IS HEREBY ORDERED that the case management deadlines are extended as agreed to 5 by the parties in the above stipulation and as follows: 6 1. Last day to amend pleadings and add parties: June 1, 2018 7 2. File the interim status report: June 1, 2018 8 3. Plaintiff’s initial expert disclosure: June 1, 2018 9 4. Defendant’s initial expert disclosure: July 30, 2018 10 5. Rebuttal expert disclosure: August 31, 2018 11 6. Discovery cut off: November 27, 2018 12 7. Dispositive motions: December 28, 2018 13 8. Joint pretrial order: January 18, 2019 14 15 IT IS SO ORDERED. 16 30th day of March, 2018. DATED this _____ 17 18 19 20 21 22 23 24 25 U.S. STATES DISTRICTMAGISTRATE COURT JUDGE UNITED JUDGE Prepared and Submitted by: SNELL & WILMER L.L.P. /s/ Joshua D. Cools Joshua D. Cools Nevada Bar No. 11941 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, NV 89169 Attorneys for Defendant FORD MOTOR COMPANY 4827-0182-7680.1 26 27 28 -6-
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