Maas v. Slatsky et al, No. 2:2022cv00568 - Document 72 (D. Nev. 2023)
Court Description: ORDER Granting 71 Stipulation to Extend Discovery Deadlines. Discovery due by 11/29/2023. Motions due by 12/29/2023. Proposed Joint Pretrial Order due by 1/30/2024. Signed by Magistrate Judge Daniel J. Albregts on 4/27/2023. (Copies have been distributed pursuant to the NEF - LOE)
Download PDF
<![CDATA[
Maas v. Slatsky et al 1 2 3 4 5 6 7 8 Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 11 12 13 14 Doc. 72 LAGOMARSINO LAW ANDRE M. LAGOMARSINO, ESQ. (#6711) CORY M. FORD, ESQ. (#15042) TAYLOR N. JORGENSEN, ESQ. (#16259) 3005 W. Horizon Ridge Pkwy., #241 Henderson, Nevada 89052 Telephone: (702) 383-2864 Facsimile: (702) 383-0065 BAKER LAW OFFICES LLOYD W. BAKER, ESQ. (#6893) ANDREW BARTON, ESQ. (#12692) 500 S. Eighth Street Las Vegas, NV 89101 Telephone: (702) 360-4949 Facsimile: (702) 360-3234 CHRISTIAN MORRIS TRIAL ATTORNEYS CHRISTIAN M. MORRIS, ESQ. (#11218) 2250 Corporate Cir. #390 Henderson, NV 89074 Telephone: (702) 434-8282 christian@cmtrialattorneys.com Attorneys for Plaintiffs UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA 16 MARIAH MAAS, as Special Administrator for CASE NO.: 2:22-cv-568-DJA the Estate of Tiffany Slatsky, MARTIN SLATSKY, as parent and legal guardian of CADE SLATSKY, a minor; STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES Plaintiffs, 17 18 19 20 21 22 23 24 25 26 27 28 (SECOND REQUEST) vs. CHRISTOPHER CANDITO, an individual; ANDREW CLAPPER, an individual; NICHOLAS ROBISON, an individual; ANDREW STOCKER, an individual; STEVEN HONSOWETZ, an individual; CITY OF NORTH LAS VEGAS, a municipality; NORTH LAS VEGAS FIRE DEPARTMENT, a City of North Las Vegas agency; GNLV, LLC dba GOLDEN NUGGET HOTEL & CASINO, a Domestic Limited-Liability Company; DOMAIN PROPERTY OWNER LLC; a Foreign Limited-Liability Company; OAKTREE CAPITAL MANAGEMENT L.P.; a Foreign Limited Partnership; DOE DEFENDANTS I through XX, and ROE CORPORATIONS I through X, inclusive, Page 1 of 9 Dockets.Justia.com 1 Defendants. 2 AND ALL RELATED CLAIMS. 4 IT IS HEREBY STIPULATED AND AGREED between the parties and their undersigned 5 attorneys 1 that the discovery cut-off date of August 1, 2023, be continued for a period of one 6 hundred and twenty (120) days from the Court’s prior Order (ECF No. 54), up to and including 7 November 29, 2023, for the purpose of allowing the parties to complete written discovery, complete 8 the depositions of the remaining parties, experts, and lay witnesses, and any other discovery the 9 parties wish to conduct. Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 3 I. DISCOVERY COMPLETED TO DATE • 11 Plaintiffs served their initial disclosures on July 20, 2022. Defendants Nicholas Robison, 12 GNLV LLC, and Domain Property Owner LLC, served their initial disclosures on July 13 20, 2022. Defendants City of North Las Vegas and The North Las Vegas Fire 14 Department served their initial disclosures on July 22, 2022. Defendants Andrew Clapper 15 and Steven Honsowetz served their initial disclosures on August 19, 2022. Defendant 16 Andrew Stocker served his initial disclosures on August 23, 2022. Plaintiffs served their 17 first supplemental disclosure on September 20, 2022. Defendant Domain Property 18 Owner, LLC served their amended initial disclosures and first supplemental disclosure on 19 September 28, 2022. Plaintiffs served their second supplemental disclosure on September 20 28, 2022. Defendant Steven Honsowetz served his first supplemental disclosure on 21 September 30, 2022. Defendant Nicholas Robison served his first supplemental 22 disclosure on October 14, 2022. Defendant GNLV LLC served their amended initial 23 disclosures and first supplemental disclosure on October 14, 2022. Defendant CNLV 24 served their first supplemental disclosure on November 18, 2022. Defendant Stocker 25 served his first supplemental disclosure on December 8, 2022. Plaintiffs served their third 26 supplemental disclosure on January 6, 2023, their fourth supplemental disclosure on 27 28 Oak Tree Capital Management, L.P. was dismissed on June 29, 2022 (ECF. 34), Domain Property Owner LLC was dismissed on November 14, 2022 (ECF 51), and GNLV, LLC was dismissed on February 17, 2023 (ECF 70). 1 Page 2 of 9 1 January 19, 2023, their fifth supplemental disclosure on February 6, 2023, their sixth 2 supplemental disclosure on March 3, 2023, and their seventh supplemental disclosure on 3 March 13, 2023. Defendants CNLV and CNLVFD served their second, third, and fourth 4 supplemental disclosure on April 4, 2023. Plaintiffs served their eighth supplemental 5 disclosure on April 6, 2023. 6 • Production of Documents to all Defendants. 7 8 • Facsimile (702) 383-0065 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 On September 7, 2022, Plaintiffs Noticed the Depositions of Defendants Clapper, Honsowetz, Stocker, and Robison. 9 10 On August 31, 2022, Plaintiffs served their first set of Interrogatories and Request for • On September 8, 2022, Plaintiffs served the Henderson Police Department with a 11 Subpoena Duces Tecum. The documents were received on September 19, 2022, and 12 supplemented to all parties. 13 • On September 9, 2022, Plaintiffs served the Clark County Coroner / Medical Examiner 14 with a Subpoena Duces Tecum. The documents were received on September 14, 2022, 15 and supplemented to all parties. 16 • On September 9, 2022, Plaintiffs served the Las Vegas Nevada DEA’s Office with a 17 Subpoena Duces Tecum. The Las Vegas DEA Office asked for a thirty (30) day extension 18 on September 15, 2022, and a two (2) week extension on October 20, 2022. No 19 documents were produced in response to the Subpoena Duces Tecum. 20 • Plaintiffs’ first set of discovery requests. 21 22 • • 27 On October 14, 2022, Defendants GNLV LLC and Nicholas Robison served their responses to Plaintiffs’ first set of discovery requests. 25 26 On September 30, 2022, Defendant Steven Honsowetz served his responses to Plaintiffs’ first set of discovery requests. 23 24 On September 29, 2022, Domain Property Owner LLC served their responses to • On November 1, 2022, Defendant Andrew Stocker served his responses to Plaintiffs’ first set of discovery requests. 28 Page 3 of 9 1 • and Other Purposes to inspect Suite 5655 at The Golden Nugget Hotel and Casino. 2 3 5 Production of Documents to Plaintiffs and Defendants Clapper and Honsowetz. • Facsimile (702) 383-0065 On November 4, 2022, Plaintiffs served the Division of Counsel for the DEA with an 7 Amended Subpoena Duces Tecum. The documents were received on December 23, 2022, 8 and supplemented to all parties. • 11 • • • • • • • • 28 On February 7, 2023, Plaintiffs took the videotaped deposition of Defendant Steven Honsowetz. 26 27 On January 23, 2023, Plaintiffs served their Second Amended Deposition Notice to Defendant Andrew Stocker. 24 25 On January 6, 2023, Plaintiffs served their responses to CNLV’s First Set of Interrogatories, Requests for Admission, and Requests for Production of Documents. 22 23 On December 22, 2022, Plaintiffs served their First Amended Deposition Notices to Defendants Steven Honsowetz, Andrew Stocker, Nicholas Robison, and Andrew Clapper 20 21 On December 7, 2022, Defendant Honsowetz served his first supplemental responses to CNLV’s first set of Requests for Production of Documents. 18 19 On December 5, 2022, Defendant Honsowetz served his responses to CNLV’s first set of Interrogatories, Requests for Admissions, and Requests for Production of Documents. 16 17 On November 28, 2022, Defendant Clapper served his responses to Plaintiff’s first set of Interrogatories and Request For Production of Documents. 14 15 On November 10, 2022, Plaintiffs served the Las Vegas Metropolitan Police Department with an Amended Subpoena Duces Tecum. 12 13 On November 4, 2022, Plaintiffs served the Las Vegas Metropolitan Police Department with a Subpoena Duces Tecum. 10 Telephone (702) 383-2864 On November 4, 2022, Defendants CNLV and The North Las Vegas Fire Department served their first set of Interrogatories, Requests for Admissions, and Requests for 9 LAGOMARSINO LAW • 4 6 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 On November 3, 2022, Plaintiffs served their Request for Entry Upon Land for Inspection • On February 9, 2023, Plaintiffs’ served their Second Amended Deposition Notice to Defendant Nicholas Robison. Page 4 of 9 1 • Stocker. 2 3 • • 7 • On February 24, 2023, Plaintiffs served their Deposition Notice to Irina Hansen. 8 • On March 3, 2023, Plaintiffs served their Third Amended Deposition Notice to Defendant Nicholas Robison. 9 Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW On February 16, 2023, Plaintiffs served their Second Set of Requests for Production of Documents to Defendants Candito, Clapper, Honsowetz, Robison, Stocker, and CNLV. 6 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 On February 16, 2023, Plaintiffs served their First Set of Requests for Production of Documents to Defendant CNLVFD. 4 5 On February 9, 2023, Plaintiffs took the videotaped deposition of Defendant Andrew • Documents to Defendant CNLV. 11 12 • On March 14, 2023, Plaintiffs served their Deposition Notice to Defendant Christopher Candito. 13 14 On March 13, 2023, Plaintiffs served their Third Set of Requests for Production of • On March 14, 2023, Plaintiffs served their Second Amended Deposition Notice to Defendant Andrew Clapper. 15 16 • On March 15, 2023, Plaintiffs’ served Micha Reyes with an Subpoena Duces Tecum. 17 • On March 16, 2023, Defendant Honsowetz and Clapper served thier responses to Plaintiffs’ Second Set of Requests for Production of Documents. 18 19 • Requests for Production of Documents. 20 21 • On March 20, 2023, Defendant Stocker served his responses to Plaintiffs’ Second Set of Requests for Production of Documents. 22 23 On March 17, 2023, Defendant Robison served his responses to Plaintiffs’ Second Set of • On March 22, 2023, Plaintiffs served the International Association of Fire Fighters Local 24 1607 with an Subpoena Duces Tecum. The documents were received on March 23, 2023, 25 and supplemented to all parties 26 27 • On March 24, 2023, Plaintiffs served their Fourth Amended Deposition Notice to Defendant Nicholas Robison. 28 Page 5 of 9 1 • Requests for Production of Documents. 2 3 • Facsimile (702) 383-0065 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 On April 12, 2023, Defendant CNLV served their responses to Plaintiff’s Third Set of Requests for Production of Documents. 4 5 On April 4, 2023, Defendant CNLV served their responses to Plaintiffs Second Set of II. DISCOVERY YET TO BE COMPLETED 6 The Parties have yet to complete the following discover (individual or 30(b)(6) designees); 7 • the depositions of the remaining named parties; 8 • the depositions of fact witnesses; 9 • subpoenas duces tecum and the depositions of third party percipient witnesses; 10 • inspection of items and land pursuant to FRCP 34; 11 • expert witness disclosures and expert witness depositions; 12 • additional written discovery which may include written discovery to one another and/or additional subpoenas to third parties; and 13 Any additional discovery the parties wish to conduct. 14 • 15 The Parties reserve the right to conduct additional discovery that is permitted by the Federal 16 Rules of Civil Procedure. 17 III. 18 19 REASONS WHY REMAINING DISCOVERY HAS NOT BEEN COMPLETED While the parties have been diligent in conducting discovery in this matter, the following issues have been unavoidable: 20 This case involves multiple parties and coordinating deposition dates that work with all 21 parties has been challenging. At this time, there have been approximately 10,000 documents, seven 22 hundred and fifty (750) photos, and eleven (11) hours of video that have been produced. Due to the 23 large volume of documents produced, the parties are in the process of completing a thorough 24 document review, responding to written discovery, and properly preparing for depositions. 25 Additionally, Counsel for Defendant Clapper has suffered severe injuries from an accident 26 and is required to be on bed rest for multiple weeks. 27 Plaintiffs’ Counsel has also been called away from the office due to an immediate family 28 member’s medical issue. Counsel will be required to spend significant time away from the office in Page 6 of 9 1 the foreseeable future which has required multiple extended hospital visits, and extended medical 2 care. The medical situation is ongoing. This has significantly hindered the parties’ ability to 3 complete and conduct the necessary discovery in this case within the current deadline. 4 IV. PROPOSED EXTENDED DEADLINES 5 Discovery cut-off 6 Current Proposed 8/1/23 Wednesday, November 29, 2023 7 8 Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 11 Deadline to amend pleadings and add parties 5/3/23 Thursday, August 31, 2023 Deadline for initial expert disclosures 6/2/23 Monday, October 2, 2023 2 Deadline for rebuttal expert disclosures 7/5/23 Wednesday, November 2, 2023 12 13 14 Deadline to file dispositive motions 8/31/23 Friday, December 29, 2023 Deadline to file pre-trial order 10/2/23 Tuesday, January 30, 2024 or 30 days after the dispositive motions have been decided. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 This deadline falls on September 30, 2023, which is a Saturday. As a result, this deadline extends to the next court day, Monday October 2, 2023, by operation of FRCP. 2 Page 7 of 9 1 This request for an extension is made in good faith and joined by all the parties in this case. 2 The Request is timely pursuant to LR 26-3. Trial is not yet set in this matter and dispositive motions 3 have not yet been filed. Accordingly, this extension will not delay this case. Since this request is a 4 joint request, no party will be prejudiced. The extension will allow the parties the necessary time to 5 complete discovery. 6 7 DATED this 26th day of April, 2023. DATED this 26th day of April, 2023. LAGOMARSINO LAW LAW OFFICE OF DANIEL MARKS /s/ Andre Lagomarsino____________ ANDRE M. LAGOMARSINO, ESQ. (#6711) CORY M. FORD, ESQ. (#15042) TAYLOR N. JORGENSEN, ESQ. (#16259) 3005 W. Horizon Ridge Pkwy., #241 Henderson, Nevada 89052 Attorneys for Plaintiffs /s/ Adam Levine _______________ DANIEL MARKS, ESQ. (#2003) ADAM MARKS LEVINE, ESQ. (#4673) 610 South Ninth Street Las Vegas, Nevada 89101 Attorneys for Defendant Andrew Stocker DATED this 26th day of April, 2023. DATED this 26th day of April, 2023. LEWIS BRISBOIS BISGAARD & SMITH THE LAW OFFICES OF KRISTINA WILDEVELD AND ASSOCIATES /s/ Lisa Rasmussen __________________ LISA A. RASMUSSEN, ESQ. (#7491) 550 E. Charleston Blvd., Suite A Las Vegas, NV 89104 Attorneys for Defendant Steven Honsowetz 20 /s/ Robert Freeman____________________ ROBERT W. FREEMAN, JR., ESQ. (#3062) MATTHEW E. FREEMAN, ESQ. (#14198) 6385 S. Rainbow Blvd., Suite 600 Las Vegas, NV 89118 Attorneys for Defendants City of North Las Vegas and North Las Vegas Fire Department 21 DATED this 26th day of April, 2023. DATED this 26th day of April, 2023. 22 LAURIA TOKUNAGA GATES & LINN, BARRON & PRUITT LLP LLP 8 Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW 9 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 IT IS SO STIPULATED AND AGREED. 11 12 13 14 15 16 17 18 19 23 24 25 26 27 /s/ Raymond Gates___________________ RAYMOND GATES (#5320) 1755 Creekside Oaks Drive, Suite 240 Sacramento, CA 95833 Attorneys for Defendant Andrew Clapper /s/ Nicholas Adams____________ WILLIAM H. PRUITT, ESQ. (#6783) JOSEPH R. MESERVY, ESQ. (#14088) NICHOLAS ADAMS, ESQ. (#14813) 3890 West Ann Road North Las Vegas, NV 89031 Attorneys for Defendant Nicholas Robison 28 Page 8 of 9 1 2 DATED this 26th day of April, 2023. CHRISTOPHER CANDITO 3 4 /s/ Christopher Candito__________ Pro Se 5 6 7 8 ITIT IS IS SOSO ORDERED that the parties' Stipulation to Extend Discovery Deadlines ORDERED. (ECF No. 71) is GRANTED. By: DATED this 27th day of April, 2023. UNITED STATES DISTRICT COURT JUDGE Facsimile (702) 383-0065 10 Telephone (702) 383-2864 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 11 _________________________________ DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 9 of 9
]]>
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You
should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google
Privacy Policy and
Terms of Service apply.
