Alexander et al v. Costco Wholesale Corporation et al, No. 2:2021cv00509 - Document 30 (D. Nev. 2023)

Court Description: ORDER Granting 29 Stipulation for extension of discovery deadlines. Discovery due by 9/1/2023. Motions due by 9/29/2023. Proposed Joint Pretrial Order due by 10/31/2023. Signed by Magistrate Judge Cam Ferenbach on 4/4/2023. (Copies have been distributed pursuant to the NEF - LOE)

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Alexander et al v. Costco Wholesale Corporation et al Doc. 30 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 1 of 13 1 2 3 4 5 6 7 8 9 SAO BRADLEY S. MAINOR, ESQ. Nevada Bar No. 7434 JOSEPH J. WIRTH, ESQ. Nevada Bar No. 10280 ASH MARIE BLACKBURN, ESQ. Nevada Bar No. 14712 MAINOR WIRTH, LLP 6018 S. Ft. Apache Rd., Ste. 150 Las Vegas, Nevada 89148 Phone: (702) 464-5000 Fax: (702) 463-4440 ash@mwinjury.com Counsel for Plaintiffs 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 14 SARAH ELIZABETH ALEXANDER, an individual; ROBERT ROY ALEXANDER, an individual, 15 Plaintiffs, 16 vs. 19 20 21 STIPULATION AND ORDER TO EXTEND DISCOVERY PLAN AND SCHEDULING ORDER (FIFTH REQUEST) 17 18 Case No.: 2:21-cv-00509-APG-VCF COSTCO WHOLESALE CORPORATION dba Costco, a Foreign Corporation; VALLEY CONTAX INC., DOES I-X; and ROE BUSINESS ENTITIES XI-XX, inclusive, Defendants. 22 23 Defendants Valley Contax, Inc., by and through their counsel of record Alan W. 24 Westbrook, Esq. of Perry & Westbrook, A Professional Law Firm, and Plaintiffs Sarah Elizabeth 25 Alexander (referred to herein as “Mrs. Alexander”) and Robert Roy Alexander (referred to herein 26 27 28 as “Mr. Alexander”), by and through counsel, Bradley Mainor, Esq. and Ash Marie Blackburn, PAGE 1 OF 11 Dockets.Justia.com Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 2 of 13 1 2 Esq. of the Mainor Wirth law firm, and Defendants, Costco Wholesale Corporation (hereinafter referred to as “Costco”), by through counsel, Edgar Carranza, Esq. of the law firm Messner 3 Reeves LLP, hereby submit the instant stipulation and order to extend the Discovery Plan and 4 Scheduling Order (Fifth Request) pursuant to Local Rule II 26-4 as follows: 5 6 7 8 9 10 I. GOOD CAUSE SUPPORTING THE EXTENSION. The parties come to this Court seeking a fifth extension of the Discovery Plan and Scheduling Order governing this complicated product liability/personal injury case. The parties have diligently moved this case forward but additional discovery remains to be completed which warrants the requested extension. 11 A. SUMMARY OF EFFORTS THUS FAR. 12 As this Court is well aware, this lawsuit involves allegations that Plaintiff, Sarah Elizabeth 13 Alexander (referred to herein as “Mrs. Alexander”) suffered serious injuries to her eye after 14 wearing prescription contact lenses, which were distributed by Valley Contax and purchased from 15 Costco, as the result of an unspecified defect with the lenses. 16 On October 28, 2021, Plaintiffs filed their Complaint against Costco and Valley Contax 17 with the Eighth Judicial District Court for Clark County, Nevada. On February 17, 2021, Costco 18 filed its Answer denying Plaintiffs’ allegations and denying all liability for the injuries. On 19 February 18, 2021, Valley Contax filed its Answer denying Plaintiffs’ allegations and denying all 20 liability for the injuries claim. 21 22 23 24 25 On March 9, 2021, Plaintiffs filed their Request for Exemption from Arbitration in which they outlined their claimed injuries and alleged damages. On March 29, 2021, Costco filed its Notice of Removal and removed the matter to this Court based on diversity jurisdiction. On April 13, 2021, Costco filed its Statement Regarding Removal. The parties participated in the Fed. R. Civ. P. 26(f) conference on April 14, 2021, and filed their proposed Joint Discovery Plan and 26 Scheduling Order which was entered by this Court on April 28, 2021. 27 28 PAGE 2 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 3 of 13 1 On April 28, 2021, Plaintiff served their Initial Disclosure of Witness and Production of 2 Documents Pursuant to FRCP 26(a)(1). On May 10, 2021, Defendant Costco served their Initial 3 Disclosure of Witness and Production of Documents Pursuant to FRCP 26(a)(1). On June 10, 4 2021, Defendant Valley Contax served their Initial Disclosure of Witness and Production of 5 6 7 8 9 Documents Pursuant to FRCP 26(a)(1). Parties have exchanged their respective Fed. R. Civ. P. 26 Disclosures. In the interim, the parties have been engaged in discovery. The parties served a first set of written discovery requests to each other, some of which have been responded to. At the same time, Plaintiffs’ medical records are being secured independently directly from the 10 health care providers. As they are being produced, supplemental disclosures are being served to 11 provide the records to all parties. 12 Plaintiffs deposed Karen Crawford (Optical Manager) on January 19, 2022, Aaron 13 Whitaker (Optician at Costco) on January 25, 2022, Max Ramos (General Manager at Costco) on 14 June 9, 2022, Edgar Retana (Security Assurance Manager of Dynatec Laboratories) on July 12, 15 2022, Robert Ahern (FRCP 30(b)(6) witness for Valley Contax) on October 17, 2022, Leisha 16 Crawford (FRCP 30(b)(6) witness for Costco) on December 6, 2022, and Ellie Cleveland (Former 17 Employee of Costco) on March 15, 2023. 18 Mrs. Alexander’s deposition went forward on July 1, 2022. Mr. Alexander’s deposition 19 was also set to take place on July 1, 2022, but had to be continued due to the length of Mrs. 20 Alexander’s deposition. Mr. Alexander’s deposition took place on December 14, 2022. 21 An inspection of the right contact lens at issue in the matter was conducted on September 22 26, 2022, near San Francisco, California. Plaintiff’s counsel personally delivered the subject 23 contact lens to the laboratory. Following the inspection, Plaintiff’s expert took issue with the 24 25 26 method of testing versus the agreed upon protocol. Plaintiff has actively been working to schedule the deposition of the laboratory technician, Afaf Wensky, which has been set for May 2nd, 2023. Ms. Wensky’s deposition is important to obtain before the expert reports are due given the claims 27 of product defect. 28 PAGE 3 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 4 of 13 1 Plaintiff’s treating physician and retained expert, Dr. Eric Brooker, was also deposed on 2 September 28, 2022. During the deposition, Defense counsel identified additional medical records 3 4 that had not been disclosed and requested that Dr. Brooker’s deposition be continued. Unfortunately, due to several personal issues in Dr. Brooker’s life, all parties had difficulty 5 6 7 8 9 obtaining the additional records from his office. His deposition was finally able to go forward on February 23, 2023. Plaintiff is still treating as a result of the injuries alleged in this case so that opinions regarding her future medical treatment is still in flux. Additional treatment has been recommended 10 within the last few weeks by virtue of Plaintiff’s ongoing care by Dr. Brooker. Plaintiff is in the 11 process of obtaining and disclosing the records as quickly as possible. 12 13 Lastly, the parties have agreed to submit this matter to a private mediation with Judge Jennifer Togliatti (Ret.) on July 20, 2023. 14 B. GOOD CAUSE. 15 As indicated above, the parties have and continue to diligently depose the witnesses 16 involved in this case. They actively worked together to schedule an out-of-state inspection, have 17 hired experts, and are gathering evidence to disclose their reports. 18 Moreover, this is a significant personal injury matter that has and will continue to require 19 significant effort by both parties. Plaintiff has already identified significant past medical expenses, 20 unknown future medical expenses estimated to amount to $100,000, loss of enjoyment of life in 21 the amount of $1,000,000, past pain and suffering in the amount of $1,500,000 and future pain 22 23 24 25 and suffering in the amount of $2,500,000, to name some of the damage components identified thus far. Significant effort will be required to address each of the damage components, and the liability portion of this case. The parties have agreed to submit this matter for private mediation with Judge Jennifer 26 Togliatti (Ret.) on July 20, 2023, further warranting an extension of the discovery deadlines. 27 28 PAGE 4 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 5 of 13 1 II. DISCOVERY COMPLETED TO DATE. 2 In accordance with LR II 26-4(a), the Parties provide the following statement of discovery 3 completed to date: 4 A. Plaintiff’s Discovery. 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1. Plaintiffs’ FRCP 26 initial disclosures served 04-20-21. 2. Plaintiffs’ First Supplement to FRCP 26 initial disclosures served on 07-20-21. 3. Plaintiff, Sarah Alexander’s Answers to Costco’s First Set of Interrogatories served on 07-23-21. 4. Plaintiff, Sarah Alexander’s Responses to Costco’s Request for Production served on 07-23-21. 5. Plaintiff, Robert Roy Alexander’s Answers to Costco’s First Set of Interrogatories served on 07-23-21. 6. Plaintiff, Robert Roy Alexander’s Responses to Costco’s Request for Production served on 07-23-21. 7. Plaintiffs’ Second Supplement to FRCP 26 initial disclosures served on 08-25-21. 8. Plaintiffs’ Third Supplement to FRCP 26 initial disclosures served on 09-02-21. 9. Plaintiffs’ First Set of Requests for Production to Valley Contax served on 11-15-21. 10. Plaintiff’s First Set of Interrogatories to Defendant Valley Contax, served on 11-16-21. 11. Plaintiffs’ Fourth Supplement to FRCP 26 initial disclosures served 26 on 11-22-21. 27 28 12. Plaintiffs’ First Set of Interrogatories to Costco served on 11-23.21. PAGE 5 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 6 of 13 1 13. Plaintiff’s Fifth Supplement to FRCP 26 initial disclosures served 2 on 12-10-21. 3 14. Plaintiff noticed the deposition of Aaron Whitaker on 12-14-21. 4 15. Plaintiff noticed the deposition of Karen Crawford on 12-14-21. 5 6 7 8 9 16. Plaintiff Answers to Defendant Valley Contax’s First Set of Interrogatories served on 2-18-22. 17. Plaintiff Responses to Defendant Valley Contax’s First Set of Production of Documents served on 2-18-22. 10 18. Plaintiff Responses to Defendant Valley Contax’s First Set of Request for 11 Admissions served on 2-18-22. 12 19. Plaintiff noticed the deposition of Max Ramos on 4-11-22. 13 20. Plaintiffs’ Sixth Supplement to FRCP 26 initial disclosures served 14 on 5-23-22. 15 21. Plaintiff noticed the deposition of Robert Ahern on 6-8-22. 16 22. Plaintiff noticed the deposition of Edgar Retana on 6-9-22. 17 23. Plaintiff amended the noticed deposition of Robert Ahern on 6-17-22. 18 24. Plaintiff amended the noticed deposition of Edgar Retana on 6-20-22. 19 25. Plaintiff vacated the noticed deposition of Robert Ahern on 6-22-22. 20 26. Plaintiffs’ Seventh Supplement to FRCP 26 initial disclosures served 21 22 23 24 25 26 on 6-22-22. 27. Plaintiffs’ Eighth Supplement to FRCP 26 initial disclosures served on 6-30-22. 28. Plaintiff’s First Set of Requests for Production of Documents to Defendant Costco served on 7-7-22. 29. Plaintiffs’ Ninth Supplement to FRCP 26 initial disclosures served 27 on 8-18-22. 28 PAGE 6 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 7 of 13 1 30. Plaintiffs’ Tenth Supplement to FRCP 26 initial disclosures served 2 on 9-9-22. 3 4 31. Plaintiffs’ counsel traveled to Pleasanton, CA on September 26, 2022 to deliver the right contact lens at issue in this matter to Defendants’ expert for inspection. 5 6 7 8 9 10 11 32. Plaintiffs noticed the deposition of Robert Ahern, Valley Contax’ FRCP 30(b)(6) witness on October 14, 2022. 33. Plaintiffs noticed the deposition of Costco’s FRCP 30(b)(6) witness on November 1, 2022. 34. Plaintiffs noticed the deposition of Afaf Wensky on March 23, 2023. B. Costco’s Discovery. 12 1. Costco’s FRCP 26 initial disclosures served 05-10-21. 13 2. Costco’s First Set of Interrogatories to Plaintiff, Robert Roy Alexander 14 15 16 17 18 19 20 21 22 23 24 25 26 served 05-12-21. 3. Costco’s First Set of Requests for Production to Plaintiff, Robert Roy Alexander served 05-12-21. 4. Costco’s First Set of Interrogatories to Plaintiff, Sarah Alexander served 05-12-21. 5. Costco’s First Set of Requests for Production to Plaintiff, Sarah Alexander served 05-12-21. 6. Custodian of records depositions were set for various health care providers on 08-17-21. 7. Costco’s First Supplement to FRCP 26 disclosures served on 10-04-21. 8. Costco’s Answers to First Set of Interrogatories from Plaintiff, served on 1-14-22. 9. Costco’s Responses to First Set of Requests for Production of Documents 27 served on 9-16-2022. 28 PAGE 7 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 8 of 13 1 2 3 4 10. Costco’s Second Supplement to FRCP 26 disclosures served on 11-2-2022. C. Valley Contax’s Discovery. 1. Valley Contax’s FRCP 26 initial disclosures served on June 9, 2021. 2. Valley Contax’s First Set of Interrogatories to Plaintiff, Sarah Alexander 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 on 12-30-21. 3. Valley Contax’s Request for Production of Documents to Plaintiff, Sarah Alexander on 12-30-21. 4. Valley Contax’s Request for Admissions to Plaintiff, Sarah Alexander on 12-30-21. 5. Valley Contax’s First Supplement to FRCP 26 initial disclosures served on 1-28-22. 6. Valley Contax’s Answers to Plaintiff Sarah Alexander’s First Set of Interrogatories, served on 1-31-22. 7. Valley Contax’s Responses to Plaintiff Sarah Alexander’s First Set of Request for Production of Documents, served on 1-31-22. 8. Valley Contax Second Supplement to FRCP 26 initial disclosures served on 2-11-22. 9. Valley Contax’s Third Supplement to FRCP 26 initial disclosures served on 5-19-22. 10. Valley Contax noticed the deposition of Mr. Alexander on 6-16-22. 11. Valley Contax noticed the deposition of Mrs. Alexander on 6-16-22. 12. Valley Contax’s Fourth Supplement to FRCP 26 initial disclosures served on 6-29-22. 13. Valley Contax’s Fifth Supplement to FRCP 26 initial disclosures served 26 on 7-22-22. 27 14. Valley Contax noticed the deposition of Dr. Eric Brooker on 7-29-22. 28 PAGE 8 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 9 of 13 1 15. Valley Contax noticed the deposition of Dr. Eric Brooker again on September 2 7, 13, 14, and 23, 2022. The deposition ultimately went forward on September 3 28, 2022. 4 16. Valley Contax’s Sixth Supplement to FRCP 26 initial disclosures served 5 on 10-3-22. 6 17. Valley Contax’s Supplemental Responses to Plaintiff’s 1st and 2nd Requests for 7 Production on 10-3-2022. 8 18. Valley Contax noticed the deposition of Robert Alexander on October 27, 2022 9 to take place on December 17, 2022. 10 19. Valley Contax’s Seventh Supplement to FRCP 26 initial disclosures served 11 on 10-28-22. 12 20. Valley Contax noticed the continued deposition of Dr. Eric Brooker on 13 14 September 30, 2022, but vacated the deposition on November 2, 2022, due to 15 the noticing counsel suffering from COVID. 21. Valley Contax’s Eighth Supplement to FRCP 26 initial disclosures served 16 17 on 11-29-22. 22. Valley Contax’s Ninth Supplement to FRCP 26 initial disclosures served 18 19 on 11-30-22. 20 23. Deposition of Robert Alexander went forward 12-14-2022. 21 24. Valley Contax’s Tenth Supplement to FRCP 26 initial disclosures served 22 on 1-20-2023. 23 24 25 25. Deposition of Dr. Brooker went forward 2-23-2023. III. DISCOVERY REMAINING TO BE COMPLETED. In accordance with LR II 26-4(b), the Parties provide the following statement of discovery 26 remaining to be completed: 27 28 1. Depositions of Plaintiff’s treating providers; PAGE 9 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 10 of 13 1 2. Deposition of Afaf Wensky; 2 3. Initial expert designations; 3 4. Rebuttal expert designations; 4 5. Depositions of Initial and Rebuttal Experts; 5 6. Mediation on July 20, 2023. 6 7 IV. This is a complicated and complex product defect case. Once the parties embarked on 8 9 WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED. discovery, they have been able to move this matter forward with the appropriate diligence. As 10 detailed above, significant discovery has been completed including the exchange of initial 11 disclosures, completion of multiple waves of written discovery, fact and party depositions, 12 securing independent copies of Plaintiffs’ medical records, and an out-of-state inspection. 13 All counsels have trials taking place in the spring of 2023 but have nonetheless agreed to 14 submit this matter for private mediation in July 20, 2023. Plaintiffs’ counsel has specifically been 15 scheduled to start trial with Judge Mahan on April 10, 2023. If mediation is not successful, the parties’ need time to schedule the depositions of 16 17 Plaintiff’s treating physicians and the designated experts. 18 V. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY. 19 This request for an extension of time is not sought for any improper purpose or other 20 purpose of delay. The parties respectfully submit that this constitutes good cause for the extension. 21 The following is a list of the current discovery deadlines and the parties’ proposed extended 22 23 24 25 26 27 deadlines. Scheduled Event Discovery Cut Off Amend Pleadings/Add Parties Initial Expert Disclosures Rebuttal Expert Disclosures Dispositive Motions Joint Pre-Trial Order /// 28 Current Deadline Proposed Deadline July 4, 2023 September 1, 2023 April 4, 2023 June 2, 2023 April 4, 2023 June 2, 2023 June 6, 2023 August 4, 2023 August 1, 2023 September 29, 2023 September 1, 2023 October 31, 2023 If dispositive motions are filed, the deadline for filing the joint pretrial order will be PAGE 10 OF 11 suspended until 30 days after decision on the dispositive motions or further court order. Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 11 of 13 1 This is the fifth request for extension of time in this matter and no trial date will be 2 impacted by the extension as no such trial date has been set. 3 The parties submit that the reasons set forth above constitute good cause for the requested 4 extension. 5 6 Dated this 3rd day of April, 2023. PERRY & WESTBROOK Dated this 3rd day of April, 2023. MAINOR WIRTH, LLP /s/ Alan W. Westbrook ALAN W. WESTBROOK, ESQ. Nevada Bar No. 6167 11500 S. Eastern Avenue, Ste. 140 Henderson, NV 89052 Attorney for Defendant Valley Contax Inc. /s/ Ash Marie Blackburn_________ ASH MARIE BLACKBURN, ESQ. Nevada Bar No. 14712 6018 S. Fort Apache Road, Ste. 150 Las Vegas, NV 89148 Attorney for Plaintiffs, Sarah Elizabeth Alexander and Robert Roy Alexander 7 8 9 10 11 12 13 14 15 16 17 18 Dated this 3rd day of April, 2023. MESSNER REEVES, LLP /s/ Edgar Carranza . EDGAR CARRANZA, ESQ. Nevada Bar No. 5902 8945 W. Russell Road, Suite 300 Las Vegas, NV 89148 Attorney for Defendants, Costco Wholesale 19 20 21 22 23 IT IS SO ORDERED. 4th _ April, 2023. DATED this __ ____________________________________ UNITED STATES MAGISTRATE JUDGE 24 25 26 27 28 PAGE 11 OF 11 Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 12 of 13 From: Sent: To: Cc: Subject: Edgar Carranza <ECarranza@messner.com> Friday, March 31, 2023 2:27 PM Ashlee Clark; Alan W. Westbrook; jmeacham@perrywestbrook.com; Pa Sherre s; Sco Lee Natalie Cothran; Nailah Cain; Alysse Beasley; Ash Blackburn RE: Alexander v. Costco_Media on Dates Thank you. You have my authority to include my e-signature. EDGAR CARRANZA Partner Messner Reeves LLP O: 702.363.5100 E: ecarranza@messner.com 8945 W. Russell Road, Suite 300, Las Vegas, NV 89148 From: Ashlee Clark <aclark@mwinjury.com> Sent: Friday, March 31, 2023 11:40 AM To: Edgar Carranza <ECarranza@messner.com>; Alan W. Westbrook <awestbrook@perrywestbrook.com>; jmeacham@perrywestbrook.com; Pa Sherre s <PSherre s@messner.com>; Sco Lee <slee@perrywestbrook.com> Cc: Natalie Cothran <Natalie@mwinjury.com>; Nailah Cain <ncain@mwinjury.com>; Alysse Beasley <Alysse@mwinjury.com>; Ash Blackburn <Ash@mwinjury.com> Subject: RE: Alexander v. Costco_Media on Dates [ EXTERNAL EMAIL ] Hello All, All revisions have been made. Please review the a ached, and con rm if I have permission to e-sign on your behalf. Warm Regards, Ashlee Clark Ashlee Clark, Paralegal MAINOR WIRTH, LLP 6018 S. Ft. Apache Rd. | Suite 150 Las Vegas, Nevada 89148 Tel: 702.464.5000 | Fax: 702.463.4440 aclark@mwinjury.com MAIL CONFIDENTIALITY NOTICE: The contents of this e-mail message and any attachments are intended solely for the addressee(s) and may contain confidential and/or legally privileged information. Case 2:21-cv-00509-APG-VCF Document 30 Filed 04/04/23 Page 13 of 13 From: Sent: To: Cc: Subject: Alan W. Westbrook <awestbrook@perrywestbrook.com> Friday, March 31, 2023 2:27 PM Edgar Carranza; Ashlee Clark; jmeacham@perrywestbrook.com; Pa Sherre s; Sco Lee Natalie Cothran; Nailah Cain; Alysse Beasley; Ash Blackburn Re: Alexander v. Costco_Media on Dates You have my approval as well. Alan On 3/31/2023 2:26 PM, Edgar Carranza wrote: Thank you. You have my authority to include my e-signature. EDGAR CARRANZA Partner Messner Reeves LLP O: 702.363.5100 E: ecarranza@messner.com 8945 W. Russell Road, Suite 300, Las Vegas, NV 89148 From: Ashlee Clark <aclark@mwinjury.com> Sent: Friday, March 31, 2023 11:40 AM To: Edgar Carranza <ECarranza@messner.com>; Alan W. Westbrook <awestbrook@perrywestbrook.com>; jmeacham@perrywestbrook.com; Pa Sherre s <PSherre s@messner.com>; Sco Lee <slee@perrywestbrook.com> Cc: Natalie Cothran <Natalie@mwinjury.com>; Nailah Cain <ncain@mwinjury.com>; Alysse Beasley <Alysse@mwinjury.com>; Ash Blackburn <Ash@mwinjury.com> Subject: RE: Alexander v. Costco_Media on Dates [ EXTERNAL EMAIL ] Hello All, All revisions have been made. Please review the a ached, and con rm if I have permission to e-sign on your behalf. Warm Regards, Ashlee Clark Ashlee Clark, Paralegal MAINOR WIRTH, LLP 6018 S. Ft. Apache Rd. | Suite 150 Las Vegas, Nevada 89148

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