Community Schools Initiative v. Vanguard Field Strategies, LLC, No. 2:2023cv00069 - Document 61 (D. Nev. 2024)

Court Description: ORDER granting 60 Stipulation to extend discovery. Discovery due by 7/12/2024. Motions due by 8/11/2024. Proposed Joint Pretrial Order due by 9/10/2024. Signed by Magistrate Judge Elayna J. Youchah on 3/13/2024. (Copies have been distributed pursuant to the NEF - MAM)

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Community Schools Initiative v. Vanguard Field Strategies, LLC Doc. 61 JEFFREY F. BARR, ESQ. Nevada Bar No. 7269 2 ASHCRAFT & BARR LLP 8275 S Eastern Ave, Suite 200 3 Las Vegas, NV 89123 4 Telephone: (702) 631-7555 mailto:barrj@ashcraftbarr.com 1 5 Bradley Bodamer (pro hac vice) George R. Lewis (pro hac vice) GRAVES GARRETT LLC 7 1100 Main Street, Suite 2700 Kansas City, Missouri 64105 8 Telephone (816) 256-3181 bbodamer@gravesgarrett.com 9 glewis@gravesgarrett.com 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 6 10 Attorneys for Defendants 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA 12 13 14 LEX TECNICA, LTD., and COMMUNITY SCHOOLS INITIATIVE 15 16 17 Case No.: 23-CV-00069-APG-EJY Plaintiff, STIPULATION AND ORDER TO EXTEND DISCOVERY (Third Request) vs. VANGUARD FIELD LLC, and AXIOM LLC STRATEGIES, 18 Defendants. 19 20 Pursuant to Local Rules IA-6-1 and 26-3, and for good cause shown, Plaintiffs Lex 21 Tecnica, Ltd., (“Lex Tecnica”) and Community Schools Initiative (collectively, “Plaintiffs) 22 and Defendants Vanguard Field Services, LLC (“Vanguard”) and Axiom Strategies, LLC 23 (“Axiom”) (collectively, “Defendants”) (collectively, the “Parties”) jointly and respectfully 24 request an extension of the following scheduling deadlines in this case (see ECF No. 55): 25 /// 26 /// 27 Page 1 of 6 Dockets.Justia.com 1 2 3 4 Deadline Description Rebuttal Expert Disclosure Discovery Cutoff Dispositive Motions Joint Pretrial Order 5 Current Deadline March 13, 2024 May 13, 2024 June 12, 2024 July 12, 2024 or 30 days after resolution of dispositive motions Proposed Deadline May 12, 2024 July 12, 2024 August 11, 2024 September 10, 2024 or 30 days after resolution of dispositive motions 6 7 In support of this stipulation, the Parties State as follows: 8 BACKGROUND 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 9 1. On January 17, 2024, the Court denied Defendants Motion to Dismiss and gave 10 Lex Tenica leave to add Community Schools Initiative as a party by February 16, 2024. ECF 11 No. 53. 12 13 2. On February 2, 2024, the Parties requested a thirty (30) day extension in order to 14 add Community Schools Initiative as a party, schedule depositions of Plaintiff’s expert 15 witnesses, and to coordinate further depositions. ECF No. 54. 16 3. The Court granted the request that same day. ECF No. 55. 17 4. On February 16, 2024, Plaintiffs filed their Third Amended Complaint, adding 18 Community Schools Initiative as a party. ECF No. 56. 19 5. On February 28 and 29, 2024, Defendants deposed Plaintiffs’ experts. 20 21 6. The Parties are still coordinating at least eleven planned depositions. 22 7. Pursuant to the operative Stipulation and Order to Extend Discovery (Second 23 Request) (ECF No. 55), the Parties have until March 13 to disclose rebuttal expert witnesses 24 and May 13, 2024, to complete discovery. See id. This current rebuttal expert disclosure 25 deadline and the other discovery deadlines that follow are no longer feasible given the current 26 posture of the case. 27 Page 2 of 6 1 2 3 GOOD CAUSE FOR EXTENDING THE REMAINING DISCOVERY DEADLINES 8. Plaintiffs added an additional party on February 16, 2024, and filed a Third Amended Complaint. 4 9. Additionally, Plaintiffs’ experts were deposed on February 28 and 29, 2024. 5 10. Further, eleven depositions (seven for Plaintiffs (at the moment) and four for 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 6 7 Defendants (at the moment)) of both Parties witnesses are being scheduled currently, but due 8 to the availability of both counsel and witnesses, dates have not yet been set. Many of the 9 anticipated depositions will take place in Las Vegas, Nevada, but at least one (and possibly 10 more) will take place in Houston, Texas, further necessitating coordination of schedules and 11 travel arrangements. 12 11. As a result of the foregoing, the Parties jointly and respectfully request extensions 13 of the scheduling order deadlines identified in the chart above. The extensions will allow the 14 Parties to complete the discovery outlined above. 15 LOCAL RULE STATEMENTS 16 17 18 19 20 12. The Parties bring this stipulation in the interest of justice and not for the purpose of undue delay. 13. Pursuant to LR 26-3 and IA 6-1, the Parties state that this is the third request they have made to extend the discovery deadlines in this case. 21 14. Pursuant to LR 26-3, the Parties submit that there is good cause for this stipulation 22 as set forth above. 23 24 25 15. Pursuant to LR 26-3(a), the Parties state that the following discovery has been completed to date: 26 a. On May 24, 2023, Lex Tecnica served its first set of requests for 27 production on Vanguard. Page 3 of 6 1 2 b. On May 24, 2023, Lex Tecnica served its first set of interrogatories on c. On July 5, 2023, Vanguard and Axiom served their initial disclosures on Vanguard. 3 4 Lex Tecnica. 5 d. On August 11, 2023, Vanguard and Axiom served their first requests for 6 7 production on Lex Tecnica. e. 8 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 9 subpoena Community Schools Initiative. 10 11 On August 11, 2023, Vanguard and Axiom served their notice of intent to f. On August 21, 2023, Lex Tecnica served its initial disclosure on Vanguard and Axiom. 12 g. On September 20, 2023, Vanguard and Axiom served their responses to 13 Lex Tecnica’s first set of requests for production. 14 h. On September 20, 2023, Vanguard and Axiom served their responses to 15 16 Lex Tecnica’s first set of interrogatories. i. 17 18 disclosures on Vanguard and Axiom. 19 20 On September 24, 2023, Lex Tecnica served its first supplemental j. On September 24, 2023, Lex Tecnica served its responses to Vanguard and Axiom’s first set of requests for production. 21 k. On January 12, 2024, Lex Tecnica served its disclosure of expert 22 witnesses and expert reports. 23 l. On January 16, 2024, Lex Tecnica took the deposition of Tami Romo. 25 m. On January 17, 2024, Lex Tecnica took the deposition of Joe Williams. 26 n. On January 18, 2024, Lex Tecnica took the deposition of Whitney 24 27 LaJaunie. Page 4 of 6 o. 1 2 On February 21, 2024, Lex Tecnica served its second supplemental disclosures on Vanguard and Axiom 3 p. On February 28, 2024, Vangaurd and Axiom took the deposition of 4 Richard MacLean. 5 q. On February 29, 2024, Vanguard and Axiom took the deposition of Kory 6 7 Langhofer. 16. Pursuant to Local Rule 26-3(b) the Parties state that one or more of the Parties 8 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 9 anticipate that at least the following discovery remains to be completed: 10 a. Supplemental disclosure to the Parties’ respective written discovery. 11 b. Additional written discovery from the Parties. c. Rebuttal expert witness disclosures and reports. d. Deposition of rebuttal expert witnesses. e. Depositions of percipient witnesses. . 12 13 14 15 17. Pursuant to Local Rule 26-3(c) Defendants refer the Court to Paragraphs 8-11 16 17 above. 18 18. Pursuant to Local Rule 26-3(d), the Parties have proposed a schedule identified 19 in the chart at the beginning of this stipulation for the completion of discovery and for the 20 extension of the other case management deadlines. 21 /// 22 /// 23 24 /// 25 26 27 Page 5 of 6 1 WHEREFORE, pursuant to Local Rules IA 6-1 and 26-3, and for good cause shown, 2 the Parties jointly and respectfully request an extension of the scheduling order deadlines 3 identified in the chart at the beginning of this motion. 4 IT IS SO STIPULATED. 5 Respectfully submitted this 13th day of March, 2024. 6 TAKOS LAW GROUP, LTD. /s/ Zachary P. Takos 8 Zachary P. Takos, Esq., Nevada Bar No. 11293 10785 W. Twain Avenue, Suite 224 9 Las Vegas, Nevada 89135 8275 SOUTH EASTERN AVENUE • STE 200-695 • LAS VEGAS, NV 89123 ASHCRAFT &BARR| LLP 7 10 LEX TECNICA, LTD. Sam Castor, Esq., Nevada Bar No. 11532 11 10161 Park Run Drive 12 Las Vegas, Nevada 89145 13 14 Counsel for Plaintiff ASHCRAFT BARR LLP /s/ Jeffrey F. Barr Jeffrey F. Barr, Esq., Nevada Bar No. 7269 8275 S. Eastern Avenue, Suite 200 695 Las Vegas, Nevada 89123 GRAVES GARRETT LLC A. Bradley Bodamer, Esq. (pro hac vice) George R. Lewis, Esq. (pro hac vice) 1100 Main Street, Suite 2700 Kansas City, MO 64105 Counsel for Defendants IT IS SO ORDERED 15 16 17 UNITED STATES MAGISTRATE JUDGE 18 DATE: 19 20 21 22 23 24 25 26 27 Page 6 of 6 March 13, 2024

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