Wong et al v. Las Vegas Sands Corp. et al, No. 2:2022cv00622 - Document 47 (D. Nev. 2023)

Court Description: ORDER Granting 46 Stipulation to Extend Deadlines. Discovery due by 2/15/2024. Motions due by 3/15/2024. Proposed Joint Pretrial Order due by 4/15/2024. Signed by Magistrate Judge Elayna J. Youchah on 11/21/2023. (Copies have been distributed pursuant to the NEF - AMMi)

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Wong et al v. Las Vegas Sands Corp. et al 1 2 3 4 5 Doc. 47 ERRICK M. FERRAN (Local Counsel) (SBN 9554) HITZKE & FERRAN, LLP 2110 E. Flamingo Road, Suite 206 Las Vegas, NV 89119 Phone: (702) 476-9668 Fax: (702) 462-2646 Email: erick.ferran@hitzkelaw.com Attorneys for Plaintiff JUDY WONG 6 7 8 9 10 11 12 LAW OFFICES OF JOHNNY L. GRIFFIN, II JOHNNY L. GRIFFIN, III (Admitted By Petition) (Cal. SBN 118694) MANOLO OLASO (Admitted By Petition) (Cal. SBN 195629) 1010 F Street, Suite 200 Sacramento, CA 95814 Phone: (916) 444-5557 Fax: (916) 444-5558 Email: jgriffin@johnnygriffinlaw.com; molaso@johnnygriffinlaw.com Attorneys for Plaintiff JUDY WONG 13 14 15 16 17 18 Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 19 20 21 22 23 24 Plaintiff William Wong In Pro Per P.O. Box 466 Meadow Vista, CA 95722 Email: william.s.wong12@gmail.com MICHAEL M. EDWARDS, ESQ. Nevada Bar No. 6281 DAVID P. PRITCHETT, ESQ. Nevada Bar No. 10959 FREEMAN MATHIS & GARY, LLP 770 E. Warm Springs Rd., Ste. 360 Las Vegas, Nevada 89119 Tel.: (725) 258-7360 michael.edwards@fmglaw.com david.pritchett@fmglaw.com Attorneys for Defendants, Las Vegas Sands Corp., Las Vegas Sands, LLC, and Venetian Casino Resort, LLC 25 Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 1 Dockets.Justia.com 1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 JUDY WONG, et al., 4 Plaintiff, 5 vs. 6 LAS VEGAS SANDS CORP.; et al., 7 Defendants. 8 9 ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:22-CV-00622-RFB-EJY FOURTH STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES; LR 26-3 Complaint filed: April 13, 2022 Answer Filed: March 27, 2023 Joint Pretrial Order Due: February 14, 2024 Before the Honorable Richard F. Boulware, II 10 Pursuant to Local Rule LR 26-3, IT IS HEREBY STIPULATED AND AGREED by and 11 12 among Defendants, LAS VEGAS SANDS CORP., LAS VEGAS SANDS, LLC, and VENETIAN 13 CASINO RESORT, LLC ("Defendants"), by and through their counsel of record; Plaintiff, JUDY 14 WONG by and through her counsel of record; and WILLIAM WONG in pro per, that the current 15 discovery deadlines be extended in the above-referenced matter. 16 This is the fourth stipulation to extend discovery deadlines. An initial extension by 17 stipulation was ordered on December 20, 2022. The first stipulation to extend discovery deadlines 18 Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 19 was necessary because Defendants had not received Plaintiff's medical records from her medical providers despite Plaintiff providing defendants with HIPAA authorizations, and despite Defendants 20 exercising diligence. A second extension, pursuant to stipulation, was ordered on May 19, 2023. A 21 third stipulated extension was ordered on July 31, 2023. The current fact discovery deadline is 22 December 15, 2023.1 23 24 25 1 The original fact discovery deadline was March 21, 2023 pursuant to the discovery plan approved by the Court on August 19, 2022, which was then extended to September 18, 2023 in connection with the second stipulation, which was then extended to December 15, 2023 by a third stipulation. Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 2 1 Discovery That Has Already Been Completed 2 On August 19, 2022, Defendants served their initial disclosure of documents and witnesses, 3 pursuant to FRCP 26(a)(1). Defendants have served ten supplemental disclosures of documents and 4 witnesses. 5 On August 19, 2022, Plaintiff, JUDY WONG served her initial disclosure of documents and 6 witnesses, pursuant to FRCP 26(a)(1). 7 On September 30, 2022, Plaintiff, Judy Wong served written discovery requests on the 8 Defendants. On November 11, 2022, Defendants served their responses to Plaintiff's written 9 10 11 discovery requests. On October 10, 2022, Plaintiff provided Defendants with HIPAA authorizations to obtain 12 her medical records. Defendants have diligently attempted to obtain Plaintiff's records; however, as 13 of December 14, 2022, Defendants had only received medical imaging films and reports, and 14 Plaintiff's medical billing. 15 On October 25, 2022, Defendants provided Plaintiff with a proposed Stipulated Protective 16 Order and Confidentiality Agreement, intended to protect certain documents to be disclosed to 17 18 Plaintiff. Plaintiff, JUDY WONG and Plaintiff WILLIAM WONG agreed to the proposed Stipulated Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 19 Protective Order. The Stipulate Protective Order was signed by the Court on December 16, 2022. 20 On April 20, 2023, the parties exchanged initial expert disclosures/designations. 21 On July 18, 2023, Defendants took JUDY WONG’S deposition. On July 19, 2023, 22 23 24 25 Defendants took WILLIAM WONG’S deposition. On October 3, 2023, Defendants took JUDY WONG’s treating medical provider’s (Paul S. Hong, M.D.) deposition. Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 3 1 2 On October 11, 2023 Defendants received JUDY WONG’S Sutter Health physical therapy records dating back to 2014, via subpoena. 3 Discovery That Remains to be Completed 4 Defendants, exercising reasonable diligence, determined that they need JUDY WONG’S 5 records dating back to 2007, particularly in connection with a 2007 MRI of her neck.2 6 Plaintiff has agreed to supplement her initial disclosures and responses to written discovery 7 requests within thirty (30) days of the requested sixty-day extension. 8 Retrieval and review of JUDY WONG’S complete medical records are critical and 9 10 11 necessary to all parties to supplement expert reports3, prepare for possible expert deposition(s), and for trial. Specifically, Defendants require additional time to receive JUDY WONG’S medical 12 records dating back to 2007 so that they can provide the records to their expert who can then 13 supplement his expert report. 14 JUDY WONG also requires additional time to review and supplement her discovery 15 responses and disclosures: specifically, by providing the required verification(s), providing damages 16 calculations, and submitting a request to Sutter Health Group to disclose to Defendants’ counsel 17 18 records that date back to 2007. JUDY WONG ALSO requires additional time to review and potentially update her discovery responses without the Defendants filing a motion to compel. JUDY Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 19 WONG is committed to completing her discovery obligations on or before January 15, 2024. 20 21 22 23 24 25 2 On or about May 4, 2023, Plaintiff JUDY WONG provided additional medical release authorizations to Defendants in connection with her Sutter Group Sacramento medical provider records so that Defendants could obtain copies. Despite this, Sutter Group Sacramento did not promptly provide records to Defendants. JUDY WONG has experienced her own difficulty obtaining complete medical records from her own health group, despite her repeated requests. 3 Instead of asking for a 90 day extension, the parties ask for a 60 day extension, with all sides committed to completing discovery within 60 days. However, in the event that cannot be accomplished by the parties, despite the exercise of reasonable diligence, it is possible the parties may seek another extension. Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 4 1 REASONS FOR NOT COMPLETING DISCOVERY 2 The parties require additional time to allow Defendants to obtain Plaintiff's relevant medical 3 records given the prior history of difficulty of retrieving records from the Sacramento Sutter Health 4 Group. 5 Given the size of this litigation and the issues at stake, the general outstanding procedural 6 uncertainty, the need to get discovery from the parties that are directly relevant to the personal 7 injury claims and defenses, and the inability to complete discovery despite diligence by the parties, 8 the parties respectfully request that the Court order an extension of the existing deadlines, as 9 10 11 proposed below. PROPOSED MODIFICATION Based on the foregoing, the parties jointly seek an order for an approximately 60-day 12 13 extension of the current deadlines. Based on the foregoing, good cause supports an extension. The 14 parties request extensions as follows: Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 15 Current Deadlines: 16 Fact discovery cut-off date: December 15, 2023 17 Dispositive motions: January 15, 2024 18 Joint pretrial order: February 14, 2024 19 Proposed New Deadlines: 20 Fact discovery cut-off date: February 15, 2024 21 Dispositive motions: March 15, 2024 22 Joint pretrial order: April 15, 2024 23 /// 24 /// 25 /// Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 5 1 This request for an extension order is made by all parties in good faith and not for the 2 purposes of delay. 3 IT IS SO STIPULATED. 4 Dated this 21st day of November 2023 Dated this 21st day of November 2023 5 /s/ David P. Pritchett________________ Michael M. Edwards, Esq. Nevada Bar No. 6281 David P. Pritchett, Esq. Nevada Bar No. 10959 770 East Warm Springs Road, Suite 360 Las Vegas, Nevada 89119 Attorneys for Defendants, Las Vegas Sands Corp., Las Vegas Sands, LLC, and Venetian Casino Resort, LLC /s/ Manolo Olaso___________________ Johnny L. Griffin, III, Esq. (Admitted by Petition) California Bar No. 118694 Manolo Olaso (Admitted by Petition) California Bar No. 195629 1010 F Street, Suite 200 Sacramento, California 95814 Attorneys for Plaintiff Judy Wong (e-signature expressly authorized on November 20, 2023) Dated this 21st day of November 2023 Dated this 21st day of November 2023 /s/ William S. Wong________________ William S. Wong In Pro Per P.O. Box 466 Meadow Vista, California 95722 (e-signature expressly authorized on November 20, 2023) /s/ Erick Ferran____________________ Erick Ferran, Esq. Nevada Bar No. 9554 2110 E. Flamingo Road, Suite 206 Las Vegas, Nevada 89119 (Local Counsel sponsoring Johnny L. Griffin, III and Manolo Olaso) Attorneys for Plaintiff Judy Wong (e-signature expressly authorized on November 20, 2023) 6 7 8 9 10 11 12 13 14 15 16 17 18 Law Offices of Johnny L. Griffin III 1010 F Street, Suite 200; Sacramento, CA 95814 (916) 444-5557 www.johnnygriffinlaw.com 19 20 21 22 23 IT IS SO ORDERED: _________________________________ ELAYNA J. YOUCHAH UNITED STATES MAGISTRATE JUDGE DATED: November 21, 2023 24 25 Judy Wong, et al. v. Las Vegas Sands Corp., et al.; Case No. 2:22-cv-00622-RFB-EJY Fourth Stipulation and [Proposed] Order Extending Deadlines 6

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