McGee v. Eurpac Services, Inc., No. 2:2020cv00334 - Document 21 (D. Nev. 2020)
Court Description: ORDER granting 20 STIPULATION FOR EXTENSION OF TIME (Second Request) re Discovery Plan and Scheduling Order re 19 Min Order. Discovery due by 1/25/2021. Motions due by 2/23/2021. Proposed Joint Pretrial Order due by 3/23/2021. Signed by Magistrate Judge Brenda Weksler on 8/13/2020. (Copies have been distributed pursuant to the NEF - DRS)
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McGee v. Eurpac Services, Inc. Doc. 21 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 1 of 7 1 DARRELL D. DENNIS Nevada Bar No. 006618 2 Darrell.Dennis@lewisbrisbois.com STEPHANIE GARABEDIAN 3 Nevada Bar No. 009612 Stephanie.Garabedian@lewisbrisbois.com 4 MICHAEL R. SMITH Nevada Bar No.12461 5 LEWIS BRISBOIS BISGAARD & SMITH LLP 6385 S. Rainbow Boulevard, Suite 600 6 Las Vegas, Nevada 89118 702.893.3383 7 FAX: 702.893.3789 Attorneys for Defendant Eurpac Service, Inc. 8 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 EARLY MCGEE, individually, CASE NO.: 2:20-cv-00334-RFB-BNW 12 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER Plaintiff, 13 vs. 14 EURPAC SERVICE, INC., a Connecticut 15 Corporation; DOES I-X; and ROE CORPORATIONS I-X, inclusive, 16 Defendant. 17 18 (Second Request) Plaintiff, EARLY MCGEE, by and through her attorneys of record, ADAM SMITH 19 LAW, and Defendant, EURPAC SERVICES, INC., by and through its attorneys of record 20 LEWIS BRISBOIS BISGAARD & SMITH LLP, hereby request that the discovery deadlines 21 in the previously filed DEFENDANT’S EMERGENCY MOTION TO EXTEND 22 DISCOVERY DEADLINES [Doc.15], be extended by ninety (90) days, pursuant to FRCP 23 29 and LR-26.4, as follows: 24 A. 25 The parties have conducted the following discovery to date: 26 1. Participation in the FRCP 26(f) Conference; 27 LEWIS DISCOVERY WHICH HAS BEEN COMPLETED 2. Plaintiff has propounded Requests for Admissions, Request for 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4837-9020-3847.1 Dockets.Justia.com Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 2 of 7 1 Production and Interrogatories and Defendant has answered; 2 3. Defendant has propounded Interrogatories, Requests for Production, 3 and Requests for Admission. Plaintiff has answered; 4 4. Plaintiff has disclosed her Initial FRCP 26(a)(1) Disclosure of Witnesses 5 and Documents; 6 5. Defendant 7 disclosed and First through Third 10 Defendant was able to obtain documents from Class Six through a 11 Freedom of Information Act Request. 12 B. 13 DISCOVERY WHICH REMAINS TO BE CONDUCTED 1. Deposition of Defendant; 14 2. Obtaining Plaintiff’s Medical Records; 15 3. Depositions of Plaintiff’s Medical Providers; 16 17 4. Initial Expert and Rebuttal Expert Disclosures; 18 5. Depositions of Plaintiff’s Expert Witnesses; 19 6. Depositions of Defendant’s Expert Witnesses; 20 7. Service of Subpoena to Nellis Airforce Base (currently closed due to 21 COVID-19 Pandemic); 22 8. Site Inspection of the Nellis Airforce Base Exchange- Class Six; 23 9. Additional Written Discovery; and 24 10. Any Additional Discovery Deemed Necessary. 25 27 REASONS WHY THE PROPOSED DISCOVERY PLAN WAS NOT COMPLETED PRIOR TO THE EXPIRATION FO THE CURRENT DISCOVERY DEADLINE 28 The parties have been working diligently to complete discovery. Plaintiff has 26 C. BRISBOIS ATTORNEYS AT LAW Initial 6. Defendant deposed Plaintiff; and 9 BISGAARD & SMITH LLP their Supplemental FRCP 26(a)(1) Disclosures; 8 LEWIS has 4837-9020-3847.1 2 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 3 of 7 1 responded to Defendant’s written discovery, and Defendant has attempted to request and 2 subpoena Plaintiff’s medical records. Due to the restrictions imposed by the current 3 4 5 6 7 COVID-19 Pandemic, Nellis Airforce Base is currently closed, and the parties have been unable to serve a subpoena for relevant information and/or schedule a site inspection. Defendant will obtain medical records and then parties will be able to schedule the deposition of Defendant. The parties will schedule the depositions of disclosed medical 8 experts, and Plaintiff’s treating physicians. The parties respectfully request an extension. D. 9 10 PROPOSED PLAN FOR COMPLETING DISCOVERY EVENT CURRENT DEADLINE PROPOSED DEADLINE Discovery Deadline October 26, 2020 January 25, 2021 Amend Pleading/Add Parties July 28, 2020 October 26, 2020 Initial Expert Disclosures August 26, 2020 November 24, 2020 Rebuttal Expert Disclosures September 26, 2020 December 18, 2020 17 File Dispositive Motions November 25, 2020 February 23, 2021 18 Pre-Trial Order December 23, 2020 March 23, 2021 11 12 13 14 15 16 19 E. 20 THE CURRENT TRIAL DATE This matter has not been scheduled for trial. 21 22 // 23 // 24 // 25 // 26 27 LEWIS 28 // // BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4837-9020-3847.1 3 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 4 of 7 1 E. 2 This is the second request to extend discovery deadlines and continue trial date. 3 NUMBER OF REQUESTS FOR EXTENSION DATED this 11th day of August, 2020. 4 ADAM SMITH LAW 5 6 By: /s/ Christian Miles Adam D. Smith Nevada Bar No. 9690 Christian A. Miles Nevada Bar No. 13193 6130 Elton Avenue Las Veags, Nevada 89107 Attorneys for Plaintiff 7 8 9 10 11 12 LEWIS BRISBOIS BISGAARD & SMITH _ LLP 13 14 By: /s/ Michael Smith DARRELL D. DENNIS Nevada Bar No. 006618 STEPHANIE GARABEDIAN Nevada Bar No. 009612 MICHAEL R. SMITH Nevada Bar No.12461 6385 S. Rainbow Boulevard, Suite 600 Las Vegas, Nevada 89118 Tel. 702.893.3383 Attorneys for Defendant Eurpac Service Inc. 15 16 17 18 19 20 21 IT IS SO ORDERED: 22 23 _______________________________________ UNITED STATES MAGISTRATE JUDGE August 13, 2020 DATED: _______________________________ 24 25 26 27 LEWIS 28 BRISBOIS BISGAARD & SMITH LLP ATTORNEYS AT LAW 4837-9020-3847.1 4 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 5 of 7 Mercado, Gabriela From: Sent: To: Subject: Attachments: Smith, Michael R. (LV) Tuesday, August 11, 2020 9:54 AM Mercado, Gabriela FW: Mcgee v. Eurpac - Defendant's FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents McGee - Stipulation and Order to Extend Discovery Plan & Scheduling Order (2nd Request) 08.10.20 4851-7588-6535 v.1.docx Follow Up Flag: Flag Status: Follow up Flagged Categories: Follow-up w/Atty. Can you help with this? Michael Smith Attorney Las Vegas Rainbow 702.830.9017 or x7029017 From: Garabedian, Stephanie Sent: Tuesday, August 11, 2020 9:52 AM To: Smith, Michael R. (LV) <Michael.R.Smith@lewisbrisbois.com>; Quintana, Lucille <Lucille.Quintana@lewisbrisbois.com> Subject: FW: Mcgee v. Eurpac - Defendant's FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents Lucille, please file the attached Stip. OC’s permission is below. Stephanie Garabedian Partner Las Vegas Rainbow 702.693.4379 or x7024379 From: Christian Miles <christian@adamsmithlaw.com> Sent: Tuesday, August 11, 2020 9:02 AM To: Garabedian, Stephanie <Stephanie.Garabedian@lewisbrisbois.com>; Quintana, Lucille <Lucille.Quintana@lewisbrisbois.com> Cc: Smith, Michael R. (LV) <Michael.R.Smith@lewisbrisbois.com>; Grigg, Christopher <Christopher.Grigg@lewisbrisbois.com>; Lourdes Chappell <lourdes@adamsmithlaw.com>; Adam Smith <adam@adamsmithlaw.com> Subject: [EXT] RE: Mcgee v. Eurpac - Defendant's FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents External Email Good Morning Stephanie, 1 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 6 of 7 I have no objections to the SAO. You may use my e-signature to submit the document to the Court. Best Regards, Christian A. Miles ADAM SMITH LAW p: (702) 929-2289 f: (702) 960-4454 e: christian@adamsmithlaw.com 6130 Elton Ave., Las Vegas, NV 89107 www.adamsmithlaw.com From: Garabedian, Stephanie <Stephanie.Garabedian@lewisbrisbois.com> Sent: Monday, August 10, 2020 5:17 PM To: Quintana, Lucille <Lucille.Quintana@lewisbrisbois.com>; Christian Miles <christian@adamsmithlaw.com> Cc: Smith, Michael R. (LV) <Michael.R.Smith@lewisbrisbois.com>; Grigg, Christopher <Christopher.Grigg@lewisbrisbois.com>; Lourdes Chappell <lourdes@adamsmithlaw.com> Subject: RE: Mcgee v. Eurpac - Defendant's FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents Hi Christian, Pursuant to your voicemail, please find attached our proposed SAO to extend discovery. Please let us know if you approve of the Stipulation or if you would like revisions. Thank you, Stephanie Stephanie Garabedian Partner Stephanie.Garabedian@lewisbrisbois.com T: 702.693.4379 F: 702.893.3789 6385 South Rainbow Blvd., Suite 600, Las Vegas, NV 89118 | LewisBrisbois.com Representing clients from coast to coast. View our locations nationwide. This e-mail may contain or attach privileged, confidential or protected information intended only for the use of the intended recipient. If you are not the intended recipient, any review or use of it is strictly prohibited. If you have received this e-mail in error, you are required to notify the sender, then delete this email and any attachment from your computer and any of your electronic devices where the message is stored. From: Quintana, Lucille Sent: Thursday, July 9, 2020 4:46 PM To: 'christian@adamsmithlaw.com' <christian@adamsmithlaw.com>; 'lourdes@adamsmithlaw.com' <lourdes@adamsmithlaw.com> Cc: Garabedian, Stephanie <Stephanie.Garabedian@lewisbrisbois.com>; Smith, Michael R. (LV) <Michael.R.Smith@lewisbrisbois.com>; Grigg, Christopher <Christopher.Grigg@lewisbrisbois.com> 2 Case 2:20-cv-00334-RFB-BNW Document 21 20 Filed 08/14/20 08/11/20 Page 7 of 7 Subject: Mcgee v. Eurpac - Defendant's FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents Christian and Lourdes – Please find attached Defendant’s FRCP 26(a)(1)(C) Third Supplemental List of Witnesses and Disclosure of Documents. Thank you, Lucille Lucille Quintana Legal Secretary 6385 S. Rainbow Blvd. Suite 600 Las Vegas, NV 89118 lucille.quintana@lewisbrisbois.com Direct Dial: 702-693-4394 Main: 702-893-3383 Fax: 702-893-3789 3
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