Pierre-Dussaubat, Jr. v. Key Insurance Company et al, No. 2:2023cv01647 - Document 15 (D. Nev. 2023)

Court Description: ORDER Granting 14 Stipulated Discovery Plan. Discovery due by 6/10/2024. Motions due by 7/9/2024. Proposed Joint Pretrial Order due by 8/8/2024. Signed by Magistrate Judge Daniel J. Albregts on 12/20/2023. (Copies have been distributed pursuant to the NEF - AMMi)

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Pierre-Dussaubat, Jr. v. Key Insurance Company et al 1 2 3 4 5 6 7 8 9 DRUMMOND LAW FIRM Craig W. Drummond, Esq. Nevada Bar No. 11109 Liberty A. Pardee (Ringor), Esq. Nevada Bar No. 14417 Joseph A. Tutone, Esq. Nevada Bar No. 16333 3325 W. Sahara Avenue Las Vegas, NV 89102 T: (702) 366-9966 F: (702) 508-9440 Craig@DrummondFirm.com Liberty@DrummondFirm.com Joey@DrummondFirm.com Attorneys for Plaintiff DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM 10 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Doc. 15 JEAN PIERRE-DUSSAUBAT, JR., individually; Plaintiff, vs. KEY INSURANCE COMPANY, a foreign corporation; EARL MCFARLANE, an individual; DOES I-V; and ROE CORPORATIONS VI-X, inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:23 -cv-01647-JCM-DJA STIPULATED JOINT DISCOVERY PLAN AND SCHEDULING ORDER PURSUANT TO FRCP 26(f) AND LOCAL RULE 26-1(b) Plaintiff, JEAN PIERRE-DUSSAUBAT, JR., by and through his attorneys, CRAIG W. DRUMMOND, ESQ., and LIBERTY A. PARDEE, ESQ., of DRUMMOND LAW FIRM, and Defendant KEY INSURANCE COMPANY, by and through its attorneys of record, PHILIP GOODHART, ESQ. of THORNDAL ARMSTRONG, PC, hereby respectfully submit their Stipulated Discovery Plan and Scheduling Order pursuant to FRCP 26(f) and Local Rule 26-1(b). Page 1 Dockets.Justia.com 1 Deadlines that fall on a Saturday, Sunday, or legal holiday have been scheduled for the next 2 judicial day. 3 A. 4 conferred by telephone on November 6, 2023 at 11:00 a.m. and was attended by: 5 Liberty A. Pardee, Esq., of the Drummond Law Firm, on behalf of the Plaintiff, and 6 Philip Goodhart, Esq. of Thorndal Armstrong, PC on behalf of the Defendant Key 7 Insurance Company. 8 B. 9 Initial Disclosures: Pursuant to FRCP 26(a)(1), the parties will make their prediscovery disclosures, including any and all information required by FRCP 26(a)(1) 10 DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM FRCP 26(f) Meeting: Pursuant to FRCP 26(f) and LR 26-1(a), the parties on or before December 6, 2023. 11 C. Discovery Plan: Discovery does not need to be conducted in phases. The parties 12 jointly proposed the following discovery plan: 13 a. Subject of Discovery: Discovery will be needed on the following subjects: All 14 claims set forth in Plaintiff’s Complaint and Defendant’s defenses asserted 15 thereto. 16 b. Discovery Cut-Off Date(s): Discovery will take 180 days, measured from the 17 date Defendant filed its Answer to Plaintiff’s Complaint, December 12, 2023. 18 Therefore, all discovery must be completed by Monday, June 10, 2024. 1 19 c. Amending the Pleadings and Adding Parties: The date of filing motions to 20 amend pleadings or to add parties shall not be later than 90 days prior to the 21 close of discovery. In this action, the last date to file motions to amend the 22 pleadings or add parties shall be Monday, March 11, 2024. 23 d. FRCP 26(a)(2) Disclosures (Experts): The last day to disclose expert 24 witnesses shall be 60 days before the discovery cut-off date. In this action, the 25 last date to disclose experts shall be Wednesday, April 10, 2024. The date of 26 the disclosure of rebuttal expert witnesses shall be 30 days after the initial 27 28 1 The 180 deadline falls on Sunday, June 9, 2024. Page 2 1 disclosure of experts. In this action, the last date to disclose rebuttal experts 2 shall be Friday, May 10, 2024. 3 e. Dispositive Motions: The last date to file dispositive motions shall not be later 4 than 30 days after the discovery cut-off date. In this action, the last date to file 5 dispositive motions shall be Tuesday, July 9, 2024. 6 f. Pretrial Order: The Joint Pretrial Order shall be filed no later than 30 days 7 after the date set for filing dispositive motions. In this action, the joint pretrial 8 order shall be filed on or before Thursday, August 8, 2024. If dispositive 9 motions are timely filed, the date for filing the Joint Pretrial Order shall be DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM 10 suspended. 11 g. FRCP 26(a)(3) Disclosures: The disclosures required by FRCP 26(a)(3) and 12 any objections thereto shall be included in the Joint Pretrial Order. 13 h. Alternative-Dispute Resolution: The parties certify that they met and 14 conferred about the possibility of using alternative-dispute resolution processes 15 including mediation, arbitration, and if applicable, early neutral evaluation 16 pursuant to LR 26-1(b)(7). 17 i. Alternative Forms of Case Disposition: The parties certify that they 18 considered and did not consent to trial by magistrate judge under 28 U.S.C. § 19 636(c) and Fed. R. Civ. P. 73 and the use of the Short Trial Program (General 20 Order 2013-01). 21 j. Electronic Evidence: The parties certify that they discussed whether they 22 intend to present evidence in electronic format to jurors for the purposes of jury 23 deliberations. The parties will enter into stipulations before trial about 24 providing discovery in an electronic format compatible with the Court’s 25 electronic jury evidence display system. 26 D. Consent to Service by Electronic Means through Electronic Mail: The 27 undersigned, on behalf of Plaintiff, hereby consents to service of documents by 28 electronic means, via electronic mail and/or facsimile, and/or by U.S. mail. The Page 3 1 undersigned, on behalf of Defendant, consents to service of documents by 2 electronic means, via electronic mail and/or facsimile, and/or by U.S. mail. 3 1. Plaintiff’s Attorneys: 4 E-Service Addresses: craig@drummondfirm.com 5 liberty@drummondfirm.com 6 joey@drummondfirm.com 7 Facsimile Number: 8 2. Defendant’s Attorneys: Thorndal Armstrong 9 E-service addresses: png@thorndal.com Facsimile Number (702) 366-0327 10 DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM Drummond Law Firm 11 12 (702) 508-9440 The undersigned also acknowledge that this consent does not require service by electronic means unless the serving party elects to do so. 13 14 15 16 17 18 19 20 21 22 DRUMMOND LAW FIRM THORNDAL ARMSTRONG DATED this _____ 18th day of December, 2023. DATED this _____ 18th day of December, 2023. /s/ Craig W. Drummond, Esq. By ______________________________ Craig W. Drummond, Esq. Nevada Bar No. 11109 Liberty A. Pardee (Ringor), Esq. Nevada Bar No. 14417 Joseph A. Tutone, Esq. Nevada Bar No. 16333 3325 W. Sahara Avenue Las Vegas, Nevada 89102 Attorneys for Plaintiff By ______________________________ /s/ Philip Goodhart, Esq. Philip Goodhart, Esq. Nevada Bar No. 5332 1100 East Bridger Avenue Las Vegas, Nevada 89101 Attorney for Defendant 23 24 25 26 27 28 Page 4 DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM 1 ORDER 2 1. The discovery cut-off shall be Monday, June 10, 2024. 3 2. Amending the Pleadings and Adding Parties. The last date for filing motions to amend 4 pleadings or to add parties shall not be later than 90 days prior to the close of discovery. In 5 this action, the last date to file motions to amend the pleadings or add parties shall be 6 Monday, March 11, 2024. 7 3. FRCP 26(a)(2) Disclosure (Experts). The last day to disclose expert witnesses shall be 60 8 days before the discovery cut-off date. In this action, the last date to disclose experts shall 9 be Wednesday, April 10, 2024. The date for the disclosure of rebuttal expert witnesses 10 shall be 30 days after the initial disclosure of experts. In this action, the last date to 11 disclose rebuttal experts shall be Friday, May 10, 2024. 12 4. Dispositive Motions. The last date to file dispositive motions shall not be later than 30 13 days after the discovery cut-off date. In this action, the last date to file dispositive motions 14 shall be Tuesday, July 9, 2024. 15 5. Joint Pretrial Order. The Joint Pretrial Order shall be filed no later than 30 days after the 16 date set for filing dispositive motions. In this action, the joint pretrial order shall be filed 17 on or before Thursday, August 8, 2024. 18 6. FRCP 26(a)(3) Disclosures. The disclosures required by FRCP 26(a)(3) and any 19 objections thereto shall be included in the Joint Pretrial Order. 20 IT IS SO ORDERED. 21 22 23 24 25 26 December 20, 2023 DATED: _____________________ DANIEL ALBREGTS UNITED J. STATES MAGISTRATE JUDGE UNITED STATES MAGISTRATE JUDGE 27 28 Page 5 1 2 3 4 5 6 7 8 9 CERTIFICATE OF SERVICE 18th day of December, 2023, the undersigned served I HEREBY CERTIFY that on this ______ the foregoing STIPULATED JOINT DISCOVERY PLAN AND SCHEDULING ORDER PURSUANT TO FRCP 26(f) and LOCAL RULE 26-1(b) on all counsel herein by causing a true copy to be served via the CM/ECF system, which was served via electronic transmission. THORNDAL ARMSTRONG Philip Goodhart, Esq. 1100 E. Bridger Avenue Las Vegas, Nevada 89101 Attorney for Defendant DRUMMOND LAW FIRM 3325 W. SAHARA AVENUE LAS VEGAS, NV 89102 WWW.DRUMMONDFIRM.COM 10 11 12 /s/ Teri Boykin _________________________________ An Employee of Drummond Law Firm 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 6

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