Hedgepeth v. Meiborg Bros, Inc. et al, No. 2:2024cv00045 - Document 16 (D. Nev. 2024)

Court Description: ORDER granting 15 Discovery Plan and Scheduling Order. Discovery due by 6/25/2024. Motions due by 7/25/2024. Proposed Joint Pretrial Order due by 8/26/2024. Signed by Magistrate Judge Maximiliano D. Couvillier, III on 3/7/2024. (Copies have been distributed pursuant to the NEF - CAH)

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Hedgepeth v. Meiborg Bros, Inc. et al 1 2 3 4 5 6 7 Doc. 16 DENNIS M. PRINCE Nevada Bar No. 5092 ANGELA M. LEE Nevada Bar No. 14905 PRINCE LAW GROUP 10801 W. Charleston Blvd., Suite 560 Las Vegas, NV 89148 Tel: 702-534-7600 Fax: 702-534-7601 E-Mail: eservice@thedplg.com Attorneys for Plaintiff Tiffany Hedgepeth 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 TIFFANY HEDGEPETH, an individual, 12 13 14 15 16 17 18 Plaintiff, CASE NO.: 2:24-cv-00045-CDS-MDC JOINT DISCOVERY PLAN AND [PROPOSED] SCHEDULING ORDER vs. MEIBORG BROS, INC., an Illinois Corporation; MEIBORG, INC., an Illinois Corporation; JAMES RAY COX, an individual; DOES I through X, inclusive; ROE BUSINESS ENTITIES I through X, inclusive, [SUBMITTED IN COMPLIANCE WITH LR 26-1(B)] Defendants. 19 20 The parties, by and through their counsel of record, hereby submit the following 21 22 23 24 Joint Discovery Plan and [Proposed] Scheduling Order pursuant to Rule 26(f)(3) and LR 26-1: A. COX answered to Plaintiffs TIFFANY HEDGEPETH complaint on December 28, 25 2023. 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Answer. Defendants MEIBORG BROS., INC., MEIBORG, INC., and JAMES RAY B. Meeting. Pursuant to Fed. R. Civ. P. 26(f) and LR 26-1(a), a meeting was held on February 2, 2024 at 3:00 p.m. was attended by: Page 1 of 5 Dockets.Justia.com 1 2 Plaintiff’s counsel: Angela M. Lee of PRINCE LAW GROUP, appearing on behalf of Plaintiff TIFFANY HEDGEPETH (“Plaintiff”). 3 Defendant’s counsel: Robert Thompson of RESNICK & LOUIS, P.C. appearing on 4 behalf of Defendants MEIBORG BROS., INC., MEIBORG, INC., and JAMES RAY COX 5 (“Defendants”). 6 C. 7 February 15, 2024. Defendants produced their Initial Disclosures on Friday, 8 February 16, 2024. 9 D. 10 Initial Disclosures. Plaintiff produced her Initial Disclosures on Thursday, Discovery Plan. Discovery does not need to be conducted in phases. The parties jointly propose to the Court the following discovery plan: 11 1. Subject of Discovery. The parties agree that the areas of discovery should 12 include, but not be limited to: all claims and defenses allowed pursuant to the Federal 13 Rules of Civil Procedure. 14 2. Discovery Cut-Off Date(s). Discovery will take 180 days, measured from the 15 date the first defendant answers or appears, which means all discovery must be 16 completed by Tuesday, June 25, 2024. 17 3. Amending the Pleadings and Adding Parties. The last date for filing 18 motions to amend pleadings or to add parties shall not be later than 90 days prior to the 19 close of discovery. In this action, the last date to file motions to amend the pleadings or 20 add parties shall be Wednesday, March 27, 2024. 21 4. FRCP 26(a)(2) Disclosures (Experts). The last day to disclose expert 22 witnesses shall be 60 days before the discovery cut-off date. In this action, the last date 23 to disclose experts shall be Friday, April 26, 2024. The date for the disclosure of rebuttal 24 expert witnesses shall be 30 days after the initial disclosure of experts. In this action, the 25 last date to disclose rebuttal experts shall be Monday, May 27, 2024 (actual due date 26 is Sunday, May 26, 2024). 27 ... 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Page 2 of 5 1 5. Dispositive Motions. The last date to file dispositive motions shall not be 2 later than 30 days after the discovery cut-off date. In this action, the last date to file 3 dispositive motions shall be Thursday, July 25, 2024. 4 6. Joint Pretrial Order. The Joint Pretrial Order shall be filed no later than 30 5 days after the date set for filing dispositive motions. In this action, the joint pretrial order 6 shall be filed on or before Monday, August 26, 2024 (actual due date is Saturday, 7 August 24, 2024). If dispositive motions are timely filed, the date for filing the Joint 8 Pretrial Order shall be suspended. 9 10 7. FRCP 26(a)(3) Disclosures. The disclosures required by FRCP 26(a)(3) and any objections thereto shall be included in the Joint Pretrial Order. 11 8. Alternative-Dispute Resolution. The parties certify that they met and 12 conferred about the possibility of using alternative-dispute resolution processes including 13 mediation, arbitration, and if applicable, early neutral evaluation pursuant to LR 26- 14 1(b)(7). 15 9. Alternative Forms of Case Disposition. The parties certify that they 16 considered and did not consent to trial by magistrate judge under 28 U.S.C. § 636(c) and 17 Fed. R. Civ. P. 73 and the use of the Short Trial Program (General Order 2013-01). 18 10. Electronic Evidence. The parties certify that they discussed whether they 19 intend to present evidence in electronic format to jurors for the purposes of jury 20 deliberations. The parties will enter into stipulations before trial about providing 21 discovery in an electronic format compatible with the Court’s electronic jury evidence 22 display system. 23 E. 24 on behalf of Plaintiff and Defendants, hereby consent to service of documents by 25 electronic means via electronic mail and/or facsimile and/or by U.S. Mail. 26 27 Consent to Service by Electronic Means through Electronic Mail. The undersigned, Documents served by electronic means must be transmitted to the following person at the e-mail address and/or facsimile number below: 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Page 3 of 5 1 1. Plaintiffs’ Attorneys: 2 E-Service Address: dprince@thedplg.com, alee@thedplg.com, 3 eservice@thedplg.com 4 Facsimile Number: 702-534-7601 5 2. Defendant’s Attorneys: Resnick & Louis, P.C. 6 E-Service Address: mroose@rlattorneys.com, rthompson@rlattorneys.com, 7 sjackson@rlattorneys.com, balexander@rlattorneys.com, 8 mmorrow@rlattorneys.com 9 Facsimile Number: 702-997-3800 10 DATED: March 5, 2024 DATED: March 5, 2024 11 PRINCE LAW GROUP RESNICK & LOUIS, P.C. /s/ Dennis M. Prince _______________________ DENNIS M. PRINCE Nevada Bar No. 5092 ANGELA M. LEE Nevada Bar No. 14905 ANDREW R. BROWN Nevada Bar No. 15875 10801 W. Charleston Blvd., Suite 560 Las Vegas, NV 89148 Attorneys for Plaintiff /s/ Robert L. Thompson _______________________ ROBERT L. THOMPSON Nevada Bar No. 9920 MELISSA J. ROOSE Nevada Bar No. 7889 8945 W. Russell Road. Ste. 330 Las Vegas, NV 89148 Attorneys for Defendants 12 13 14 15 16 17 18 19 ORDER 20 IT IS SO ORDERED. 21 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Prince Law Group 22 1. The discovery cut-off shall be Tuesday, June 25, 2024. 23 2. Amending the Pleadings and Adding Parties. The last date for filing motions to 24 amend pleadings or to add parties shall not be later than 90 days prior to the close of 25 discovery. In this action, the last date to file motions to amend the pleadings or add 26 parties shall be Wednesday, March 27, 2024. 27 3. 28 shall be 60 days before the discovery cut-off date. In this action, the last date to disclose FRCP 26(a)(2) Disclosures (Experts). The last day to disclose expert witnesses Page 4 of 5 1 experts shall be Friday, April 26, 2024. The date for the disclosure of rebuttal expert 2 witnesses shall be 30 days after the initial disclosure of experts. In this action, the last 3 date to disclose rebuttal experts shall be Monday, May 27, 2024. 4 4. 5 30 days after the discovery cut-off date. In this action, the last date to file dispositive 6 motions shall be Thursday, July 25, 2024. 7 5. 8 after the date set for filing dispositive motions. In this action, the joint pretrial order 9 shall be filed on or before Monday, August 26, 2024. Dispositive Motions. The last date to file dispositive motions shall not be later than Joint Pretrial Order. The Joint Pretrial Order shall be filed no later than 30 days 10 6. 11 objections thereto shall be included in the Joint Pretrial Order. 12 13 FRCP 26(a)(3) Disclosures. The disclosures required by FRCP 26(a)(3) and any 3-7-24 DATED: _______________________________ 14 15 16 _______________________________________ UNITED STATES MAGISTRATE JUDGE 17 18 19 20 21 22 23 24 25 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Page 5 of 5

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