Maas v. Slatsky et al, No. 2:2022cv00568 - Document 79 (D. Nev. 2023)
Court Description: ORDER granting 78 Stipulation to Extend Discovery Deadlines. Discovery due by 2/27/2024. Motions due by 3/28/2024. Proposed Joint Pretrial Order due by 4/29/2024. Signed by Magistrate Judge Daniel J. Albregts on 8/3/2023. (Copies have been distributed pursuant to the NEF - CT)
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Maas v. Slatsky et al Doc. 79 Case 2:22-cv-00568-GMN-DJA Document 78 Filed 08/02/23 Page 1 of 9 1 2 3 4 5 6 7 8 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 Facsimile (702) 383-0065 10 11 12 13 Telephone (702) 383-2864 14 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 -GMN-DJA 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 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 28 (THIRD 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 Case 2:22-cv-00568-GMN-DJA Document 78 Filed 08/02/23 Page 2 of 9 1 Defendants. 2 AND ALL RELATED CLAIMS. 3 IT IS HEREBY STIPULATED AND AGREED between the parties and their undersigned 4 5 days from the Court’s prior Order (ECF No. 72), up to and including February 27, 2024, for the 7 purpose of allowing the parties to complete written discovery, complete the depositions of the 8 remaining parties, experts, and lay witnesses, and any other discovery the parties wish to conduct. 9 I. Facsimile (702) 383-0065 10 12 13 14 Telephone (702) 383-2864 DISCOVERY COMPLETED TO DATE • 11 15 16 17 18 19 20 21 22 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 6 attorneys1 that the discovery cut-off date of August 1, 2023, be continued for a period of ninety (90) Plaintiffs served their initial disclosures on July 20, 2022. Defendants Nicholas Robison, GNLV LLC, and Domain Property Owner LLC, served their initial disclosures on July 20, 2022. Defendants City of North Las Vegas and The North Las Vegas Fire Department served their initial disclosures on July 22, 2022. Defendants Andrew Clapper and Steven Honsowetz served their initial disclosures on August 19, 2022. Defendant Andrew Stocker served his initial disclosures on August 23, 2022. Plaintiffs served their first supplemental disclosure on September 20, 2022. Defendant Domain Property Owner, LLC served their amended initial disclosures and first supplemental disclosure on September 28, 2022. Plaintiffs served their second supplemental disclosure on September 28, 2022. Defendant Steven Honsowetz served his first supplemental disclosure on September 30, 2022. Defendant Nicholas Robison served his first supplemental disclosure on October 14, 2022. Defendant GNLV LLC served their amended initial disclosures and first supplemental disclosure on October 14, 2022. Defendant CNLV served their first supplemental disclosure on November 18, 2022. Defendant Stocker served his first supplemental disclosure on December 8, 2022. Plaintiffs served their third supplemental disclosure on January 6, 2023, their fourth supplemental disclosure on January 19, 2023, their fifth supplemental disclosure on February 6, 2023, their sixth supplemental disclosure on March 3, 2023, and their seventh supplemental disclosure on March 13, 2023. Defendants CNLV and CNLVFD served their second, third, and fourth supplemental disclosure on April 4, 2023. Plaintiffs served their eighth supplemental disclosure on April 6, 2023. Defendants CNLV & CNLFVD served their fifth supplemental disclosure on May 19, 2023. Plaintiffs served their ninth supplementa disclosure on June 15, 2023. Defendants CNVL and CNLVFD served their sixth supplemental disclosure on June 22, 2023 and their seventh supplemental disclosure on July 24, 2023. 25 26 27 28 1 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), GNLV, LLC was dismissed on February 17, 2023 (ECF 70), and Steven Honsowetz was dismissed on May 3, 2023 (ECF. No 74) Page 2 of 9 1 2 • On August 31, 2022, Plaintiffs served their first set of Interrogatories and Request for Production of Documents to all Defendants. • On September 7, 2022, Plaintiffs Noticed the Depositions of Defendants Clapper, Honsowetz, Stocker, and Robison. • On September 8, 2022, Plaintiffs served the Henderson Police Department with a Subpoena Duces Tecum. The documents were received on September 19, 2022, and supplemented to all parties. • On September 9, 2022, Plaintiffs served the Clark County Coroner / Medical Examiner with a Subpoena Duces Tecum. The documents were received on September 14, 2022, and supplemented to all parties. • On September 9, 2022, Plaintiffs served the Las Vegas Nevada DEA’s Office with a Subpoena Duces Tecum. The Las Vegas DEA Office asked for a thirty (30) day extension on September 15, 2022, and a two (2) week extension on October 20, 2022. No documents were produced in response to the Subpoena Duces Tecum. • On September 29, 2022, Domain Property Owner LLC served their responses to Plaintiffs’ first set of discovery requests. • On September 30, 2022, Defendant Steven Honsowetz served his responses to Plaintiffs’ first set of discovery requests. • On October 14, 2022, Defendants GNLV LLC and Nicholas Robison served their responses to Plaintiffs’ first set of discovery requests. • On November 1, 2022, Defendant Andrew Stocker served his responses to Plaintiffs’ first set of discovery requests. • On November 3, 2022, Plaintiffs served their Request for Entry Upon Land for Inspection and Other Purposes to inspect Suite 5655 at The Golden Nugget Hotel and Casino. • 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 Production of Documents to Plaintiffs and Defendants Clapper and Honsowetz. • On November 4, 2022, Plaintiffs served the Division of Counsel for the DEA with an Amended Subpoena Duces Tecum. The documents were received on December 23, 2022, and supplemented to all parties. On November 4, 2022, Plaintiffs served the Las Vegas Metropolitan Police Department with a Subpoena Duces Tecum. 3 4 5 6 7 8 Facsimile (702) 383-0065 10 11 12 13 Telephone (702) 383-2864 14 15 16 17 18 19 20 21 22 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 • • On November 10, 2022, Plaintiffs served the Las Vegas Metropolitan Police Department with an Amended Subpoena Duces Tecum. 28 Page 3 of 9 1 2 • On November 28, 2022, Defendant Clapper served his responses to Plaintiff’s first set of Interrogatories and Request For Production of Documents. • 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. • On December 7, 2022, Defendant Honsowetz served his first supplemental responses to CNLV’s first set of Requests for Production of Documents. • On December 22, 2022, Plaintiffs served their First Amended Deposition Notices to Defendants Steven Honsowetz, Andrew Stocker, Nicholas Robison, and Andrew Clapper. • On January 6, 2023, Plaintiffs served their responses to CNLV’s First Set of Interrogatories, Requests for Admission, and Requests for Production of Documents. • On January 23, 2023, Plaintiffs served their Second Amended Deposition Notice to Defendant Andrew Stocker. • On February 7, 2023, Plaintiffs took the videotaped deposition of Defendant Steven Honsowetz. • On February 9, 2023, Plaintiffs’ served their Second Amended Deposition Notice to Defendant Nicholas Robison. • On February 9, 2023, Plaintiffs took the videotaped deposition of Defendant Andrew Stocker. • On February 16, 2023, Plaintiffs served their First Set of Requests for Production of Documents to Defendant CNLVFD. • On February 16, 2023, Plaintiffs served their Second Set of Requests for Production of Documents to Defendants Candito, Clapper, Honsowetz, Robison, Stocker, and CNLV. • On February 24, 2023, Plaintiffs served their Deposition Notice to Irina Hansen. • On March 3, 2023, Plaintiffs served their Third Amended Deposition Notice to Defendant Nicholas Robison. • On March 13, 2023, Plaintiffs served their Third Set of Requests for Production of Documents to Defendant CNLV. • On March 14, 2023, Plaintiffs served their Deposition Notice to Defendant Christopher Candito. • On March 14, 2023, Plaintiffs served their Second Amended Deposition Notice to Defendant Andrew Clapper. 3 4 5 6 7 8 Facsimile (702) 383-0065 10 11 12 13 Telephone (702) 383-2864 14 15 16 17 18 19 20 21 22 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 28 Page 4 of 9 1 2 • On March 15, 2023, Plaintiffs’ served Micha Reyes with an Subpoena Duces Tecum. • On March 16, 2023, Defendant Honsowetz and Clapper served their responses to Plaintiffs’ Second Set of Requests for Production of Documents. • On March 17, 2023, Defendant Robison served his responses to Plaintiffs’ Second Set of Requests for Production of Documents. • On March 20, 2023, Defendant Stocker served his responses to Plaintiffs’ Second Set of Requests for Production of Documents. • On March 22, 2023, Plaintiffs served the International Association of Fire Fighters Local 1607 with an Subpoena Duces Tecum. The documents were received on March 23, 2023, and supplemented to all parties. • On March 24, 2023, Plaintiffs served their Fourth Amended Deposition Notice to Defendant Nicholas Robison. • On April 4, 2023, Defendant CNLV served their responses to Plaintiffs Second Set of Requests for Production of Documents. • On April 12, 2023, Defendant CNLV served their responses to Plaintiff’s Third Set of Requests for Production of Documents. • On April 17, 2023, Plaintiffs served their Notice of Deposition of Micah Reyes. • On April 27, 2023, Plaintiffs served their First Amended Notice of Deposition of Defendant Candito, their Third Amended Notice of Deposition of Andrew Clapper, and their First Amended Notice of Deposition of Micah Reyes. • On May 15, 2023, Defendant CNLV served their Notice of Deposition for Plaintiff Mariah Maas and Tamara Slatsky. • On May 24, 2023, Defendant CNLV served their Notice of Deposition for Plaintiff Martin Slatsky. • On May 24, 2023, Plaintiffs served their Fifth Amended Notice of Deposition to Defendant Robison. • On June 15, 2023, Plaintiffs served their Third Set of Request of Production of Documents to Defendants Robison, Clapper, Stocker, and Candito and served their Fourth Set of Requests for Production of Documents to Defendant CNLV. • On July 14, 2023, Defendants Robison and Clapper served their responses to Plaintiffs’ Third Set of Requests for Production of Documents. 3 4 5 6 7 8 Facsimile (702) 383-0065 10 11 12 13 Telephone (702) 383-2864 14 15 16 17 18 19 20 21 22 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 28 Page 5 of 9 1 2 • On July 24, 2023, Defendant CNLV served their responses to Plaintiffs’ Fourth Set of Requests for Production of Documents. • On July 24, 2023, Defendant Robison served his First Supplemental Response to Plaintiffs’ First Set of Requests for Production of Documents. 3 Facsimile (702) 383-0065 Telephone (702) 383-2864 II. DISCOVERY YET TO BE COMPLETED 5 The Parties have yet to complete the following discovery (individual or 30(b)(6) designees); 6 • the depositions of the remaining named parties; 7 • the depositions of fact witnesses; 8 • subpoenas duces tecum and the depositions of third party percipient witnesses; 9 • inspection of items and land pursuant to FRCP 34; 10 • expert witness disclosures and expert witness depositions; 11 • additional written discovery which may include written discovery to one another and/or additional subpoenas to third parties; and 12 13 • 14 The Parties reserve the right to conduct additional discovery that is permitted by the Federal Any additional discovery the parties wish to conduct. 15 Rules of Civil Procedure. 16 III. 17 18 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: 19 This case involves multiple parties and coordinating deposition dates that work with all 20 parties has been challenging. At this time, there have been approximately 11,000 documents, seven 21 hundred and fifty (750) photos, and eleven (11) hours of video that have been produced. Due to the 22 large volume of documents produced, the parties are in the process of completing a thorough 23 document review, responding to written discovery, and properly preparing for depositions. 24 Plaintiffs’ counsel has a twenty-five (25) day trial set in the Los Angeles Superior Court, 25 starting on August 1, 2023, and a ten (10) day trial immediately following on September 12, 2023 in 26 the U.S. District Court of Nevada. This has significantly hindered the parties’ ability to complete and 27 conduct the necessary discovery in this case within the current deadline. 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 4 28 Page 6 of 9 1 IV. PROPOSED EXTENDED DEADLINES 2 Discovery cut-off 3 Current Proposed 11/29/23 Tuesday, February 27, 2024 4 5 Deadline to amend pleadings and add parties 8/31/23 6 Wednesday November 29, 2023 7 Deadline for initial expert disclosures 10/2/23 Monday, January 1, 20242 Deadline for rebuttal expert disclosures 11/2/23 Wednesday, January 31, 8 2024 Facsimile (702) 383-0065 10 11 Deadline to file dispositive motions 12/29/23 Thursday, March 28, 2024 12 Deadline to file pre-trial order 1/30/24 Monday April 29, 2024 or 30 days after the dispositive motions have been decided. 13 Telephone (702) 383-2864 14 15 … 16 17 … 18 19 … 20 21 22 … 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 2 28 This deadline falls on December 31, 2023, which is a Sunday. As a result, this deadline extends to the next court day, Monday January 1, 2024, by operation of FRCP. Page 7 of 9 Case 2:22-cv-00568-GMN-DJA Document 78 Filed 08/02/23 Page 8 of 9 1 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 6 7 LAGOMARSINO LAW LAW OFFICE OF DANIEL MARKS /s/ Taylor N. Jorgensen ____________ 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 14 DATED this 2nd day of August, 2023. DATED this 2nd day of August, 2023. 15 LEWIS BRISBOIS BISGAARD & SMITH LAURIA TOKUNAGA GATES & LINN, LLP /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 /s/ Raymond Gates ______________________ RAYMOND GATES (#5320) 1755 Creekside Oaks Drive, Suite 240 Sacramento, CA 95833 Attorneys for Defendant Andrew Clapper 11 12 13 16 17 18 19 20 21 22 23 24 1 Facsimile (702) 383-0065 10 Telephone (702) 383-2864 IT IS SO STIPULATED AND AGREED. DATED this 2nd day of August, 2023. 9 LAGOMARSINO LAW complete discovery. DATED this 2nd day of August, 2023. 8 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 This request for an extension is made in good faith and joined by all the parties in this case. 25 26 27 28 Page 8 of 9 Case 2:22-cv-00568-GMN-DJA Document 78 Filed 08/02/23 Page 9 of 9 1 DATED this 2nd day of August, 2023. DATED this 2nd day of August, 2023. 2 BARRON & PRUITT LLP CHRISTOPHER CANDITO /s/ Nicholas F. 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 /s/ Christopher Candito _________________ CHRISTOPHER CANDITO Pro Se 3 4 5 6 7 8 IT IS SO ORDERED. Facsimile (702) 383-0065 10 By: 11 DANIEL J. ALBREGTS UNITED STATES DISTRICT COURT UNITED STATES MAGISTRATE JUDGE 12 DATED: 8/3/2023 13 Telephone (702) 383-2864 14 15 16 17 18 19 20 21 22 23 24 1 LAGOMARSINO LAW 3005 W. Horizon Ridge Pkwy., #241, Henderson, Nevada 89052 9 25 26 27 28 Page 9 of 9 JUDGE
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