Ansara et al v. Maldonado et al, No. 2:2019cv01394 - Document 129 (D. Nev. 2021)

Court Description: ORDER granting 128 Amended STIPULATION FOR EXTENSION OF TIME (Fourth Request) - Discovery due by 3/10/2022. Motions due by 4/7/2022. Proposed Joint Pretrial Order due by 5/9/2022. Signed by Magistrate Judge Cam Ferenbach on 8/25/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Ansara et al v. Maldonado et al Doc. 129 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 1 of 14 1 2 3 4 5 6 7 MARTIN I. MELENDREZ, ESQ. Nevada Bar No. 7818 BRITANNICA D. COLLINS, ESQ. Nevada Bar No. 13324 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Phone: (702) 318-8800 Fax: (702) 318-8801 mmelendrez@hawkinsmelendrez.com bcollins@hawkinsmelendrez.com Attorneys for Defendant Tropicana DE, LLC 8 UNITED STATE DISTRICT COURT 9 DISTRICT OF NEVADA HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 10 11 12 13 14 15 ROBERT ANSARA, as Special Administrator of the estate of D.B., born December 18, 2015, and died August 15, 2017, and GABRIELLE BRANONCHESLEY, individually, as the Natural Mother of D.B., DAVID BANKS, individually and as the Natural Father of D.B., 16 Plaintiffs, 17 18 19 20 21 22 23 24 25 26 27 28 v. GLORIA MALDONADO, individually; AUDRA GUITERREZ, individually; CLARK COUNTY, a Political Subdivision of the State of Nevada, DOE individuals IXX; ROE CLARK COUNTY DEPARTMENT OF FAMILY SERVICES EMPLOYEES I-XX, individually and in their official capacities; TROPICANA DE, LLC, d/b/a SIEGAL SUITES OF TROPICANA, a Foreign Limited Liability Corporation; AND DOE SECURITY COMPANY and ZOE CORPORATIONS XXI-XXX, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.: 2:19-CV-01394-GMN-VCF AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY (Fourth Request) Defendants. ____________________________________ 1 Dockets.Justia.com Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 2 of 14 AMENDED STIPULATION AND ORDER TO EXTEND DISCOVERY (Fourth Request) 1 2 3 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 4 IT IS HEREBY STIPULATED by and between the parties that discovery shall be extended Ninety Days (90) days until March 10, 2022. 5 This litigation arose out of an alleged wrongful death that occurred on August 15, 2017. The 6 parties have engaged in extensive motion work during the pendency of this litigation, as summarized 7 below: 8 1. Plaintiffs filed their original Complaint on (ECF No. 5) on August 14, 2019. 9 2. A First Amended Complaint (ECF No. 5) was filed on August 15, 2019. 10 3. Defendant Tropicana DE, LLC filed their Motion to Dismiss (ECF No. 16) on 11 12 September 9, 2019. 4. 13 14 21) on September 30, 2019. 5. 15 16 6. Plaintiffs filed a Motion for leave to file a Second Amended Complaint (ECF no. 31) on October 8, 2019. 7. 19 20 Defendant Tropicana filed their Reply (ECF no. 28) thereto on October 7, 2019. 17 18 Plaintiffs filed their Opposition to Defendant Tropicana’s Motion (ECF No. Defendant Richard Whitley filed a Motion to Dismiss (ECF No. 41) on October 24, 2019. 8. Defendants Clark County, Gloria Maldonado, Audra Gutierrez/Guerro, 21 Yolanda King and Tim Burch filed their Joinder to Richard Whitley’s Motion 22 to Dismiss (ECF No. 42); and their Separate Motion to Dismiss (ECF No.45) 23 on October 31, 2019. 24 9. 25 26 27 Plaintiffs filed an Opposition (ECF No. 48) to Richard Whitley’s Motion to Dismiss on November 8, 2019. 10. Defendant Richard Whitley filed a Reply to Plaintiff’s Opposition (ECF No. 50) on November 13, 2019. 28 2 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 3 of 14 1 11. 2 Yolanda King and Tim Burch filed their Joinder to Richard Whitley’s Reply 3 to Response to Motion to Dismiss (ECF. No. 52) on November 14, 2019. 4 12. 5 6 Plaintiffs filed an Opposition to Defendant Clark County’s Motion to Dismiss (ECF No. 53) on November 14, 2019. 13. Defendant Clark County, Gloria Maldonado, Audra Gutierrez/Guerro, 7 Yolanda King and Tim Burch filed their Reply to Plaintiffs’ Opposition to 8 Dismiss Plaintiffs’ First Amended Complaint (ECF no. 56) on November 26, 9 2019. 10 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 Defendant Clark County, Gloria Maldonado, Audra Gutierrez/Guerro, 14. The Court entered an Order (ECF No. 63) regarding the Motions to Dismiss 11 filed by all Defendants (ECF Nos. 16, 41, and 45) as well as Plaintiffs Motion 12 to Amend (ECF No. 31) on May 7, 2020. In that Order, the Court granted in 13 part and denied in part Defendants’ Motions as well as Plaintiffs’ Motion to 14 Amend. Specifically, the Court held that the claims against the Defendants 15 were dismissed without prejudice but that Plaintiffs’ Motion to Amend was 16 granted in part and denied in part. ECF No. 63 P. 20:1-20. Plaintiffs were 17 awarded twenty-one (21) days from the date of the Order to file a Second 18 Amended Complaint. 19 15. 2020. 20 21 Plaintiffs filed their Second Amended Complaint (ECF No. 64) on May 28, 16. A Stipulation and Order of Dismissal of Defendants Yolanda King and 22 Timothy Burch with Prejudice was signed and entered on June 5, 2020 (ECF 23 No. 69). 24 17. 25 26 27 Defendant Tropicana filed their Motion to Dismiss Plaintiffs’ Second Amended Complaint (ECF No. 70) on June 11, 2020. 18. Defendant Clark County, et. al., filed their Motion to Dismiss Plaintiffs’ Second Amended Complaint (ECF No. 72) on June 25, 2020. 28 3 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 4 of 14 1 The Stipulation and Order for Extension to Respond to Defendant Tropicana 2 DE, LLC Motion to Dismiss (ECF No. 74) was entered on June 26, 2020. This 3 stipulation granted Plaintiffs until July 27, 2020 to Oppose Defendant’s 4 Motion. 5 20. A second Stipulation and Order for Extension of Time was entered in to by 6 Plaintiffs and counsel for Defendant Tropicana. This Stipulation extended 7 Plaintiff’s time to oppose Defendant’s Motion to Dismiss Plaintiffs Second 8 Amended Complaint from July 27, 2020, until September 10, 2020. This Order 9 was entered on July 21, 2020 (ECF No. 82). 10 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 19. 21. On July 23, 2020, the Court entered an Order on the Stipulation for Extension 11 to Respond to Defendant Clark County et. al.’s Motion to Dismiss Plaintiffs 12 Second Amended Complaint (ECF No. 84). This Order granted Plaintiffs an 13 extension until August 31, 2020 to respond to said Motion. 14 22. 15 16 request (ECF No. 86). 23. 17 18 24. 25. 26. 27 On September 9, 2020, Plaintiffs filed Motion to Amend Complaint (ECF No. 91). 27. 25 26 On September 9, 2020, Plaintiffs filed Response to Motion to Dismiss (ECF No. 90). 23 24 On September 3, 2020, the Court entered an Order re extension of time (First Request) to Reply re Motion to Dismiss, (ECF No 88). 21 22 On September 1, 2020, Plaintiffs’ Response to Clark County’s Motion to Dismiss was filed (ECF No. 87). 19 20 On August 31, 2020, the Court entered an Order extending discovery - second On September 11, 2020, The Court entered Order regarding Defendant Tropicana De, LLC’s Stipulation for Substitution of Attorneys (ECF No. 93). 28. On September 16, 2020, Defendant Tropicana De, LLC filed a Reply regarding Motion to Dismiss (ECF No. 94). 28 4 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 5 of 14 1 29. 2 3 Complaint (ECF No. 95). 30. 4 5 31. 32. 33. HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 34. On October 9, 2020, Defendants Clark County, Audra Gutierrez, Gloria Maldonado filed a Reply regarding Motion to Dismiss (ECF No. 102). 35. 14 15 On October 9, 2020, Defendants Clark County, Audra Gutierrez, Gloria Maldonado filed a Response to Motion to Amend (ECF No. 101). 12 13 On October 5, 2020, Plaintiffs filed a Reply regarding Motion to Amend (ECF No. 100). 10 11 On October 5, 2020, the Court entered an Order granting Stipulation to Extend Deadline to Reply to Motion to Amend Complaint. (ECF No. 99) 8 9 On September 25, 2020, the Court entered an Order granting Extend Deadlines to Reply to Motion to Dismiss (ECF No. 97). 6 7 On September 23, 2020, Defendant filed Response to Motion to Amend On October 9, 2020, Defendants Clark County, Audra Gutierrez, Gloria Maldonado filed a Motion to Leave to File Exhibits Under Seal (ECF No. 103). 36. 16 On October 15, 2020, the Court entered an Order granting Stipulation to file Reply re Motion to Amend (ECF No. 106). 17 37. On November 10, 2020, the parties filed a Joint Status Report (ECF No. 108) 18 38. On November 20, 2020, the Court entered an Order granting Stipulation for 19 Extension of Time (Second Request) to Reply to Plaintiffs’ Countermotion to 20 Amend Complaint (ECF No. 111). 21 39. 112). 22 23 On November 20, 2020, Plaintiffs filed a Reply re Motion to Amend (ECF No. 40. On February 22, 2021, the Court entered an Order Denying Defendant 24 Tropicana’s Motion to Dismiss, Granting in Part and Denying in Part Clark 25 County Defendants’ Motion to Dismiss, Granting Clark County Defendants’ 26 Motion for Leave to File, and Denying without prejudice Plaintiff’s Motion to 27 Amend (ECF No. 113). 28 5 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 6 of 14 1 41. 2 Amended Complaint (ECF No. 114). 3 42. 4 On March 9, 2021, Defendants Clark County, Audra Gutierrez, Gloria Maldonado filed Answer to Second Amended Complaint (ECF No. 115). 5 43. 6 On March 17, 202, a Stipulation and Order to Extend Discovery (Third Request) was filed. (ECF No. 118) 7 44. 8 On March 17, 2021, an Order Granting Stipulation and Order to Extend Discovery (Third Request) was filed. (ECF No. 119). 9 45. On March 19, 2021, an Errata to Stipulation and Order to Extend Discovery (Third Request) was filed. (ECF No. 120). 10 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 On March 8, 2021, Defendant Tropicana De, LLC filed Answer to Second 11 46. 12 On March 19, 2021, a corrected filing of Second Amended Stipulation and Order to Extend Discovery (Third Request) was filed. (ECF No. 122). 13 47. on March 19, 2021, an Order Granting Second Amended Stipulation and Order 14 to Extend Discovery (Third Request) was filed. (ECF No. 123). 15 In January 2021, counsel for Plaintiffs Samantha A. Martin, Esq. found out that she was 16 pregnant with a due date in August 2021. It is Ms. Martin’s intention to take maternity leave from 17 August 2021 until the end of October/beginning of November 2021 depending on her health and the 18 health of the child. Ms. Martin will not be available for any depositions and will have limited 19 availability to review the necessary expert disclosures. Furthermore, the parties anticipate that there 20 will be numerous depositions that need to be taken to fully litigate all of the claims and defenses in 21 this matter. The ninety-day (90) day extension of time will ensure that the parties have ample time to 22 conduct any and all discovery necessary for this matter. The parties recognize that this is a lengthy 23 discovery period but given Ms. Martin’s pregnancy as well as all of the claims, leave as well as all of 24 the claims, defenses and parties at issue here, they believe that the ninety (90) day extension is 25 necessary. As such, the parties agree that an additional Ninety (90) days are needed to disclose 26 experts, complete party and witness depositions and complete discovery. 27 /// 28 /// 6 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 7 of 14 1 2 3 4 5 6 7 8 9 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 10 11 12 13 14 15 16 17 18 19 20 21 I. Discovery Completed to Date 1. A Joint Discovery Plan and Scheduling Order (ECF No. 39) was filed on October 23, 2019. 2. Plaintiff served their Initial FRCP Disclosures on October 28, 2019, and First and Second supplement on September 4, 2020. 3. Defendant Tropicana De, LLC served their Initial FRCP Disclosures on October 29, 2019. 4. Defendant Clark County, et. al. served their FRCP 26 Initial Disclosures on October 30, 2019. 5. Defendant Clark County, et. al served their FRCP 26 First Supplemental Disclosures with exhibits on February 25, 2020. 6. Plaintiffs propounded their First Set of Discovery to Defendant Tropicana on February 12, 2020and received Tropicana’s Responses on April 27, 2020. 7. Plaintiffs propounded their First Set of Written Discovery to Defendant Clark County, et. al. on February 12, 2020, and received their response on April 29, 2020. 8. Defendant Clark County, et. al. served their Second Supplemental FRCP26 disclosures and exhibits on April 29, 2020. 9. Defendant Clark County, et. al. propounded their first set of written discovery on Plaintiffs on April 21, 2020, and received their response on June 9, 2020. 10. Plaintiffs propounded Second Set of written discovery on Defendant Clark County on April 13, 2020. 22 11. Plaintiffs propounded Third Set of written discovery on Defendant Clark County on 23 June 9, 2020, and received their response on April 10, 2020, and received their 24 response on July 30, 2020. 25 26 27 28 12. Plaintiffs propounded Second Set of written discovery on Defendant Tropicana on June 11, 2020, and received their responses on August 21, 2020. 13. Defendant Clark County, et. al. served their Third Supplemental FRCP26 disclosures and exhibits on June 26, 2020, 7 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 8 of 14 1 2 3 4 5 6 7 8 9 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 10 11 12 13 14 15 16 14. Defendant Clark County, et. al. served their Fourth Supplemental FRCP26 disclosures and exhibits on July 30, 2020, 15. Defendant Clark County, et al. served their Fifth Supplemental FRCP26 disclosures and exhibits on May 20, 2021. 16. Defendant Clark County, et al. responded to Plaintiff’s Second set of Production of Documents on April 16, 2021. 17. Defendant Clark County, et al. served their Sixth Supplemental FRCP26 disclosures and exhibits on May 20, 2021. 18. Defendant Clark County, et al. served their Seventh Supplemental FRCP26 disclosures and exhibits on July 8, 2021. 19. Defendant Clark County, et al. served their Eighth Supplemental FRCP26 disclosures and exhibits on July 30, 2021. 20. The deposition of Terry Kukyendoll was set for October 6, 2020, and has been continued to October 25, 2021. 21. The deposition of Rebecca Taylor was set for October 7, 2020, but needs to be renoticed. 17 22. The deposition of Sasha Scott was set for October 7, 2020 but needs to be re-noticed. 18 23. The deposition of Gloria Maldonado is TBD. 19 24. The deposition of Audra Gutierrez is TBD. 20 25. The deposition of Tim Burch is TBD. 21 26. The deposition of Anthony Diggs is TBD. 22 27. The deposition of Valerie Shyface is TBD. 23 28. The deposition of Anne Sullivan is TBD. 24 29. The deposition of Michelle Brown is TBD. 25 30. The deposition of Traci Silva was taken July 26, 2021. 26 31. The deposition of Mark Perkinson was taken July 26, 2021. 27 32. Clark County served fourteen (14) 28 Notices of Taking Custodian of Records Deposition scheduled for August 30, 2021 (Records only by August 23, 2021). 8 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 9 of 14 1 32. Plaintiffs served their Third Supplemental FRCP26 disclosures and exhibits on July 2 30, 2021. 3 33. Plaintiffs served their Fourth supplemental FRCP26disclosures and exhibits on August 4 4, 2021. 5 II. 6 The parties discussed what additional discovery needs to be completed in this matter. It was 7 determined that, in order to fully litigate and investigate all alleged claims and defenses, the parties 8 need to engage in the following: HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 9 Description of Additional Proposed Discovery 1. Depositions of parties and witnesses. 10 2. Additional disclosure of documents and written discovery. 11 3. Retention of experts. 12 4. Disclosure of all experts and their reports as well as depositions of the same. 13 Proposed Schedule for Completing All Remaining Discovery 14 The parties wish to extend the dates for discovery as follows: Current Dates Last day to amend pleadings or add parties CLOSED Last day to serve Plaintiff’s Initial Expert September 10, 2021 Disclosures Last day to serve Defendant’s Initial Expert October 8, 2021 Disclosures Last day to serve Plaintiff’s and Defendant’s November 8, 2021 Rebuttal Expert Disclosures Last day to complete discovery December 10, 2021 Last day to file dispositive motions January 7, 2022 Joint Pretrial Order May 9, 2022 15 16 17 18 19 20 21 Proposed Dates CLOSED December 9, 2021 January 6, 2022 February 7, 2022 March 10, 2022 April 7, 2022 22 III. Reasons Why Good Cause Exists to Extend Expert Discovery Deadlines 23 FRCP 16(b)(5) provides that the scheduling order “shall not be modified” except upon 24 a showing of good cause. The purpose of this rule is “to offer a measure of certainty in pretrial 25 proceedings, ensuring that at some point both the parties and pleadings will be fixed.” Nutton v. Sunset 26 Station, Inc., Nev. Adv. Rep. 34, 357 P.3d 966, 971 (Nev. App. 2015). Good cause is established by 27 showing that the current deadline cannot be met despite the requesting party’s diligence in attempting 28 to meet said deadline. Diligence in attempting to meet a deadline may be determined by considering If dispositive motions are filed, the deadline for filing the joint pretrial order will be suspended until 30 days after decision on the dispositive motions or further court order. 9 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 10 of 14 1 the explanation for the untimely conduct; the importance of the requested untimely action; the 2 potential prejudice in allowing the untimely conduct; and the availability of a continuance to cure 3 such prejudice. Id. at 971-72. 4 As outlined above, the parties have been engaged in extensive motion work relating to 5 Plaintiffs various claims and the defenses to the same and, until recently, the parties were without an 6 operative complaint fully outlining the parties involved in the litigation and the claims against them. 7 Parties were therefore unable to take depositions of any percipient witnesses, retain experts or send 8 out written discovery narrowly tailored to the claims at issue. With the parties finally having an 9 operative complaint from which to work, discovery can truly begin in this matter. Additionally, now 10 that Ms. Martin is pregnant with a due date in August 2021, the parties are requesting additional time 11 to allow for Ms. Martin’s post-partum recovery. 12 The parties recognize that this is the fourth discovery extension requested. However, given 13 the nature of this case and the extensive motion work up to this point, the parties agree that additional 14 time is needed to complete discovery and to fully litigate this matter. This request is not being made 15 in an attempt to delay the litigation of this matter but instead is being requested as a result of the issues 16 outlined above as well as the party’s inability to fully litigate the claim up to this point. 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 10 Case 2:19-cv-01394-GMN-VCF Document 129 Filed 08/25/21 Page 11 of 14 1 2 The requested extension of time for completion of discovery will allow the parties and their counsel to fully litigate this matter. 3 4 Date:__August 24, 2021__________ RICHARD HARRIS LAW FIRM Date:____August 24, 2021__________ HAWKINS MELENDREZ, PC _/s/ Jonathan Lee______________ JONATHAN LEE, ESQ. Nevada Bar No. 013524 801 South Fourth Street Las Vegas, Nevada 89101 Attorneys for Plaintiffs /s/ Martin I. Melendrez MARTIN I. MELENDREZ, ESQ. Nevada Bar No. 7818 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Attorneys for Defendant Tropicana DE, LLC 5 6 7 8 9 HAWKINS MELENDREZ, P.C. 9555 Hillwood Drive, Suite 150 Las Vegas, Nevada 89134 Telephone (702) 318-8800 • Facsimile (702) 318-8801 10 11 12 13 14 15 16 Date:August 24, 2021 OLSON CANNON GORMLEY & STOBERSKI /s/ Felicia Galati FELICIA GALATI, ESQ. Nevada Bar No. 7341 9950 West Cheyenne Avenue Las Vegas, NV 89129 Attorneys for Defendants Clark County, Gloria Maldonado, Audra Guitierrez/Guerro, 17 18 ORDER 19 20 IT IS SO ORDERED. 21 22 23 24 ______________________________ Cam Ferenbach United States Magistrate Judge August 25, 2021 DATED ________________________ 25 26 27 28 11 Case 2:19-cv-01394-GMN-VCF Document 129 128 Filed 08/25/21 Page 12 of 14 From: Felicia Galati <fgalati@ocgas.com> Sent: Tuesday, August 24, 2021 8:25 AM To: Elizabeth Gould <Egould@hawkinsmelendrez.com>; Jonathan Lee <jlee@richardharrislaw.com> Cc: Samantha Martin <SMartin@richardharrislaw.com>; Jessica Dennis <JDennis@richardharrislaw.com>; Nicole Gilenson <Nicole@richardharrislaw.com>; Britannica Collins <bcollins@hawkinsmelendrez.com>; Martin Melendrez <mmelendrez@hawkinsmelendrez.com>; Denise Giancola <dgiancola@hawkinsmelendrez.com> Subject: RE: Ansara v Clark County - Amended SAO Extend 4th This is fine. You can e-sign for me. Thank you. Felicia Galati, Esq., Shareholder Olson Cannon Gormley & Stoberski 9950 West Cheyenne Avenue Las Vegas, Nevada 89129 PH: 702-384-4012 FX: 702-383-0701 Privileged and Confidential This email, including attachments, is intended for the person(s) or company named and may contain confidential and/or legally privileged information. Unauthorized disclosure, copying or use of this information may be unlawful and is prohibited. This email and any attachments are believed to be free of any virus or other defect that might affect any computer into which it is received and opened, and it is the responsibility of the recipient to ensure it is virus free, and no responsibility is accepted by Olson Cannon Gormley & Stoberski, for any loss of damage arising in any way from its use. If you have received this communication in error, please immediately notify the sender at 702-384-4012, or by electronic email. From: Elizabeth Gould <Egould@hawkinsmelendrez.com> Sent: Tuesday, August 24, 2021 8:15 AM To: Jonathan Lee <jlee@richardharrislaw.com>; Felicia Galati <fgalati@ocgas.com> Cc: Samantha Martin <SMartin@richardharrislaw.com>; Jessica Dennis <JDennis@richardharrislaw.com>; Nicole Gilenson <Nicole@richardharrislaw.com>; Britannica Collins <bcollins@hawkinsmelendrez.com>; Martin Melendrez <mmelendrez@hawkinsmelendrez.com>; Denise Giancola <dgiancola@hawkinsmelendrez.com> Subject: RE: Ansara v Clark County - Amended SAO Extend 4th Good Morning: Attached, please find the Amended Stipulation and Order to Extend Discovery (fourth Request). Please review and let me know if we may use your e-signature for submission to the Court. Elizabeth Lee Gould Paralegal Case 2:19-cv-01394-GMN-VCF Document 129 128 Filed 08/25/21 Page 13 of 14 9555 Hillwood Dr., Ste. 150 Las Vegas, NV 89134 Tel.: 702-318-8800 Fax.: 702-318-8801 egould@hawkinsmelendrez.com Case 2:19-cv-01394-GMN-VCF Document 129 128 Filed 08/25/21 Page 14 of 14 From: Jonathan Lee <jlee@richardharrislaw.com> Sent: Tuesday, August 24, 2021 6:19 PM To: Elizabeth Gould <Egould@hawkinsmelendrez.com>; Nicole Gilenson <Nicole@richardharrislaw.com> Cc: Denise Giancola <dgiancola@hawkinsmelendrez.com>; Martin Melendrez <mmelendrez@hawkinsmelendrez.com>; Britannica Collins <bcollins@hawkinsmelendrez.com> Subject: RE: Ansara v Clark County - Amended SAO Extend 4th Yes, you may submit. Jonathan Lee Lawyer - Partner Las Vegas 801 South 4th Street Las Vegas NV 89101 Ph. (702) 444-4444 x 229 Reno 6900 S. McCarran Blvd., #1010 Reno NV 89509 Ph. (775) 222-2222 Confidentiality Notice: This message and any attachments are for the named person's use only. The message and any attachment may contain confidential, proprietary, or privileged information. No confidentiality or privilege is waived or lost by any mistransmission. If you receive this message in error, please immediately notify the sender, delete all copies of it from your system, and destroy any hard copies of it. Please do not, directly or indirectly, use, disclose, distribute, print, or copy any part of this message if you are not the intended recipient. Further, this message shall not be considered, nor shall it constitute an electronic transaction, non-paper transaction, and/or electronic signature under any and all electronic acts including the Uniform Electronic Transfer Act and/or the Electronic Signatures in Global and National Commerce Act. From: Elizabeth Gould <Egould@hawkinsmelendrez.com> Sent: Tuesday, August 24, 2021 4:11 PM To: Jonathan Lee <jlee@richardharrislaw.com>; Nicole Gilenson <Nicole@richardharrislaw.com> Cc: Denise Giancola <dgiancola@hawkinsmelendrez.com>; Martin Melendrez <mmelendrez@hawkinsmelendrez.com>; Britannica Collins <bcollins@hawkinsmelendrez.com> Subject: FW: Ansara v Clark County - Amended SAO Extend 4th CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Good Afternoon: I am just following up on the email that I sent this morning asking if I can affix your signature on the Amended SAO. We had mistakenly changed the date for Amending pleadings, and that date had expired some time ago. As such, we are correcting that.

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