McCart-Pollak v. On Demand Direct Response LLC et al, No. 2:2020cv01624 - Document 182 (D. Nev. 2023)
Court Description: ORDER Granting 179 Discovery Plan and Scheduling Order. The Clerk of Court is directed to strike ecf no. 180 , which sets the same dates. Discovery due by 9/22/2023. Motions due by 10/23/2023. Proposed Joint Pretrial Order due by 11/22/2023. Signed by Magistrate Judge Cam Ferenbach on 2/6/2023. (Copies have been distributed pursuant to the NEF - LOE)
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McCart-Pollak v. On Demand Direct Response LLC et al Doc. 182 Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 1 of 6 1 2 Shana Lee McCart-Pollak 524 Blanche Court Henderson, Nevada 89052 (702) 439-2263 Email: Iotsoflovebuddies@yahoo.com 4 UNITED STATES DISTRICT COURT 5 DISTRICT OF NEVADA 6 7 SHANA LEE MCCART-POLLAK, Plaintiff, 8 PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING vs 10 11 12 13 14 15 Case No: 2:20-cv-01624-GMN-VCF ON DEMAND DIRECT RESPONSE LLC, Delaware company, ON DEMAND DIRECT RESPONSE III LLC, Delaware company; BRETT SAEVITZON, individual; CRAIG SHANDLER, individual; JEFFREY MILLER, individual; DOES l-X; ROE BUSINESS ENTITTIES I-X; Defendants 16 17 Pursuant to Court Order (Dkt 175), comes now, Plaintiff Shana Lee McCart-PolIa[ 18 (“Pollak”) in proper person; Brett Saevitzon and Craig Shandler through their respectivE 19 Counsel, David Dorenfeld. stipulate to the following proposed Discovery Plan anc 20 Scheduling Order 21 MEMORANDUM OF POINTS AND AUTHORITIES 22 23 On January 19, 2023 the Honorable Magistrate Judge Ferenbach ordered the thE 24 Parties had until Wednesday. February 8, 2023, to file a joint discovery plan anc 25 scheduling order. On Friday, February 3, 2023, PoIlak and Dorenfeld held a zoom mee 26 and confer and agreed to the following dates, herein, in order to allow the Parties thE 27 opportunity to conduct full discovery. 28 PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING ORDER - 1 Dockets.Justia.com Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 2 of 6 1 2 LEGAL STANDARD AND STATEMENTS Every motion or stipulation to extend or reopen discovery shall include: 3 1) A Statement specifying the discovery completed; 4 No Discovery has been completed. 6 a) Saevitzon- Has not served discovery on Pollak. 7 b) Shandler- Has not served discovery on Pollak. 8 c) Pollak- Pollak served Request for Production and Interrogatories on Saevitzor 9 Shandler, On Demand Direct Response, LLC, On Demand Direct Response Ill, 10 LLC ahd Jeffrey Miller which are not complete. 12 2) A specific description of the discovery that remains to be completed 13 Pollak plans on pursuing (Request for Admissions, Request for Production ol 14 Documents, Interrogatories, as well as Depositions) on all parties. 15 3) The reason why the discovery remaining was not completed within the time 16 limits set by the discovery order. The Court stayed discovery pending the decision on Defendants’ Motion to Dismiss. 18 19 The Court Denied Defendants’ Motion to Dismiss on October 6, 2023 (Order Dkt 163). 20 On January 19, 2023 (Order Dkt 175) the Court lifted the stay of discovery and ordered 21 that the parties file a joint discovery plan and scheduling order 22 4) A proposed schedule for completing all remaining discovery 23 24 The Partibs used a prior template (of dates and timeframes) of a Discovery 25 schedule that was previously entered in this Case; and therefore, propose the following 26 dates: 27 “ 28 PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING ORDER -2 Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 3 of 6 0 1 STIPULATED PROPOSED DISCOVERY PLAN AND SCHEDULING DEADLINES 2 Amended Pleadings: Friday, June 23, 2023, (which is 91 days before the 3 proposed Discovery cut-off date, due to the weekend) DiscoveiS’ Deadline: Friday, September 22, 2023 6 Initial Expert Disclosures: Monday, July 24, 2023, (which is 60 days before the 7 stipulated proposed Discovery cut-off date) 8 RebuttalExpert Disclosures: Wednesday, August 23, 2023 (which is 30 days 9 before the stipulated proposed Discovery cut-off date) 10 Dispositive Motions: Monday, October 23, 2023, (which is 31 days after the 11 12 stipulated proposed Discovery cut-off date) 13 Proposed Pretrial Order: Wednesay, November 22, 2023, (which is 30 days 14 after the stipulated proposed Dispositive Motions cut-off date) 15 If dispositive motions are filed, the deadline for filing the joint pretrial order will be 16 suspended until 30 days after decision on the dispositive motions or further cou 17 order. 18 19 5) The Current trial date 20 The extension of the discovery deadlines will have no bearing on trial, as no trial dat 21 has been set. 22 Conclusion 23 The Parties respectfully requests that the Court accepts this jointly stipulate 24 25 proposed Discovery Plan and Scheduling Order. 26 / 27 II 28 PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING ORDER -3 Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 4 of 6 1 .. Dated this 3rd day of February, 2023 2 /s/ Shana Lee McCart-Pollack SIGNATURE Shana Lee Mccart-Pollak 524 Blanche Court Henderson, Nevada 89052 Tel: (702) 439-2263 Email: Lotsoflovebuddies@yahoo.com 3 4 5 6 7 8 Prose Dated this) d y of February, 2023 9 SIGNATURE David K Dorenfeld (Cal. Bar No. 145056; Pro Hae Vici) DorenfeldLaw, Inc. 30101 Agoura Court, Suite 210 Agoura Hills, California 91301 Tel: (828) 865-4000 Email: david@dorenfeldlaw.com 10 11 12 13 14 15 16 17 [PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS ORDERED. 18 19 20 21 22 2-6-2023 Dated: --------- HONORABLE CAM FERENBACH UNITED STATES MAGISTRATE JUDGE The Clerk of Court is directed to strike ECF No. 180, which sets the same dates. 23 24 25 26 27 28 PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING ORDER - 4 Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 5 of 6 1 2 CERTIFICATE OF SERVICE Case Name: Shana Lee McCart-Follak v. On Demand Direct Response LLC, et at. District Court Case No.: 02:20-cv-01624-GMN-VCF 3 4 lam employed in the County of Los Angeles, State of California. lam over the age of 18 and not a party to the within action. My business address is 30101 Agoura Court, Suite 210, Agoura Hills, California 91301. 5 6 On February 3, 2023, I served the foregoing documents described as PROPOSED STIPULATION DISCOVERY PLAN AND SCHEDULING ORDER on the 7 interested parties in tlus action by placing a true and correct copy thereof enclosed in a sealed envelope addressed as follows: 8 SEE ATTACHED SERVICE LIST 9 10 ii 12 13 14 1 16 17 18 19 [By Mail] I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited in the U.S. Postal Service on that same day with postage thereon fully prepaid at Agoura Hills California, in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after the date of deposit for mailing in affidavit. [By Federal Express] I am “readily familiar” with the firm’s practice of collection and processing correspondence for mailing via Federal Express. Under that practice it would be deposited in the Federal Express pick-up box on that same day with charges thereon fully prepaid at a drop box location in Agoura Hills, California, in the ordinary course of business. — [By Electronic Servicej Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent at the electronic notification addresses above. [By Personal Service] I caused such envelope(s) to be hand-delivered to the offices of the addressee(s), during normal business hours. 20 21 22 1 declare under penalty of perjury, under the laws of the State of California, that the foregoing is true and correct. Executed February 3, 2023, at Agoura Hills, California. Rebecca Santiago 25 26 27 28 Case 2:20-cv-01624-GMN-VCF Document 182 Filed 02/06/23 Page 6 of 6 1 2 4 5 6 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SERVICE LIST Shana Lee McCart-Pollak 524 Blanche Court Henderson, NV 89052 Telephone: (702) 439-2263 E-mail: lotsoflovebuddiesyahoo.com VIA E-MAIL AND US. MAIL G. Mark Aibright Daniel R. Ormsby ALBRIGHT, STODDARD, WARNICK & ALBRIGHT 801 S. Rancho Drive, Suite D-4 Las Vegas, Ny 89106 Telephone: (792) 763-7352 Fax: (702) 384-0605 E-mail: gmaalbrightstoddard.com; dormsbycalbrightstoddard.com; emessingalbrightstoddard.com VIA E-MAIL ONLY Mark Meyers 1037 Barrow Court Westlake Village, CA 91361 VIA US. MAIL ONLY
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