Vickery v. Solomon, No. 2:2023cv00137 - Document 19 (D. Nev. 2023)
Court Description: ORDER granting 18 Stipulation TO EXTEND DISCOVERY DEADLINES. Discovery due by 2/12/2024. Motions due by 4/8/2024. Proposed Joint Pretrial Order due by 5/8/2024. Signed by Magistrate Judge Brenda Weksler on 11/21/2023. (Copies have been distributed pursuant to the NEF - CAH)
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Vickery v. Solomon 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Doc. 19 DENNIS M. PRINCE Nevada Bar No. 5092 ANGELA M. LEE Nevada Bar No. 14905 PRINCE LAW GROUP 10801 W. Charleston Blvd., Suite 560 Las Vegas, NV 89148 Tel: 702-534-7600 Fax: 702-534-7601 E-Mail: eservice@thedplg.com -andALEX J. DE CASTROVERDE Nevada Bar No. 6950 ORLANDO DE CASTRVERDE Nevada Bar No. 7320 DE CASTROVERDE LAW GROUP 1149 South Maryland Pkwy Las Vegas, NV 89104 Tel: 725-241-5730 Fax: 702-383-8741 E-Mail: orlando@decastroverdelaw.com Attorneys for Plaintiffs 15 UNITED STATES DISTRICT COURT 16 17 18 DISTRICT OF NEVADA JOYCE VICKERY, an individual, Plaintiff, 19 20 21 22 23 vs. DEMETRIC DANARD SOLOMON, an individual; DOES 1-20 and ROE BUSINESS ENTITIES 1-20, inclusive, 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES (Second Request) Defendants. 24 25 CASE NO.: 2:23-cv-00137-CDS-BNW /// /// /// /// Page 1 of 6 Dockets.Justia.com 1 STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES (Second Request) 2 3 4 5 6 7 8 9 10 11 12 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff JOYCE VICKERY (“Plaintiff”), through her counsel of record, Dennis M. Prince, Angela M. Lee and Andrew R. Brown of PRINCE LAW GROUP and Alex J. De Castroverde and Orlando De Castroverde of DE CASTROVERDE LAW GROUP; and Defendant DEMETRIC DANARD SOLOMON (“Defendant”), through his counsel of record, Darrell D. Dennis and Michael R. Smith of LEWIS BRISBOIS BISGAARD & SMITH, LLP, that the discovery deadlines shall be extended ninety (90) days pursuant to LR 26-3. This is the parties’ second request for an extension of the discovery deadlines. The parties set forth the following information in support of their stipulation. I. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 DISCOVERY COMPLETED TO DATE A. FRCP 26(a) Disclosures and Supplements Title Plaintiff’s Initial Disclosure of Documents and Witnesses Pursuant to FRCP 26(a)(1) Defendant’s Initial List of Witnesses and Disclosure of Documents Pursuant to FRCP 26(F) Plaintiff’s First Supplement to her Initial Disclosure of Documents and Witnesses Pursuant to FRCP 26(a)(1) Plaintiff’s Second Supplement to her Initial Disclosure of Documents and Witnesses Pursuant to FRCP 26(a)(1) Plaintiff’s Third Supplement to her Initial Disclosure of Documents and Witnesses Pursuant to FRCP 26(a)(1) Plaintiff’s Fourth Supplement to her Initial Disclosure of Documents and Witnesses Pursuant to FRCP 26(a)(1) B. Date Served March 29, 2023 April 11, 2023 July 7, 2023 September 5, 2023 October 12, 2023 October 18, 2023 Written Discovery Title Date Served Plaintiff’s First Set of Requests for Production of Documents to June 21, 2023 Defendant Demetric Danard Solomon Plaintiff’s First Set of Interrogatories to Defendant Demetric June 21, 2023 Danard Solomon Page 2 of 6 1 2 3 4 5 6 7 8 9 10 11 12 13 Defendant’s Responses to Plaintiff’s First Set of Request for Production of Documents Defendant’s Answers to Plaintiff’s First Set of Interrogatories Defendant’s First Set of Request for Admissions to Plaintiff Defendant’s First Set of Request for Production of Documents to Plaintiff Defendant’s First Set of Interrogatories to Plaintiff Plaintiff’s Responses to Defendant’s First Set of Request for Admissions Plaintiff’s Response to Defendant’s First Set of Request for Production of Documents Plaintiff’s Answer to Defendant’s First Set of Interrogatories C. July 28, 2023 July 28, 2023 August 24, 2023 August 24, 2023 August 24, 2023 October 10, 2023 October 10, 2023 October 10, 2023 Depositions Deponent Defendant Demetric Danard Solomon Date August 2, 2023 Officer Stephen Kircher August 3, 2023 Plaintiff Joyce N. Vickery October 13,2023 14 15 II. DISCOVERY TO BE COMPLETED 16 1. Depositions of witnesses. 17 2. The parties will retain and disclose rebuttal expert witnesses. 18 3. The parties will depose their respective expert witnesses. 19 4. The parties will engage in additional written discovery and notice any 20 additional depositions. 21 The parties anticipate that they may need to conduct other forms of discovery not 22 specifically delineated herein on an as-needed basis. Therefore, the list outlined above is 23 in no way intended to be a comprehensive list of the outstanding discovery that remains 24 to be completed. 25 III. 26 REASONS DISCOVERY WAS NOT COMPLETED WITHIN THE TIME LIMITS AND NEEDS TO BE EXTENDED 27 28 The parties respectfully request an extension of the discovery deadlines in this matter. The parties require additional time to schedule depositions, especially of the 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Page 3 of 6 1 expert witnesses. There have been many difficulties scheduling expert depositions, 2 especially during the fall/winter with various holidays and travel occurring. 3 Additionally, there is a discovery dispute with regard to certain requested documents, 4 for which the parties have been sending meet and confer letters. The parties need 5 additional time to determine whether a motion will need to be filed. 6 Although the parties have been diligently and cohesively working together to 7 complete discovery, a 90 day extension of these deadlines would provide the parties 8 additional time to ensure the parties have time to appropriately and fully litigate this 9 matter during the discovery phase. While the parties are engaged in good faith efforts to 10 coordinate depositions, they have been unable to notice the depositions in advance of the 11 current discovery deadline. In addition, while the parties are actively engaged in 12 discovery, there is insufficient time to clarify and discuss discovery disputes that have 13 arisen. 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 For these reasons, the parties believe there is good cause to extend the discovery deadlines. See LR 26-3. “[D]istrict courts . . . retain broad discretion to control their dockets . . . .” Shahrokhi v. Harter, No. 2:21-cv-01126-RFB-NJK, 2021 U.S. Dist. LEXIS 247936, at *4 (D. Nev. Dec. 30, 2021). To prevail on a request to extend discovery deadlines, the parties must establish good cause. Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 608-09 (9th Cir. 1992). For the reasons set forth above, the parties respectfully submit that good cause supports their requested stipulation for a ninety (90) day extension of the discovery deadlines. The parties’ requested extension of the discovery deadlines is not made in bad faith or to cause any unnecessary delays in the resolution of this matter, but rather to facilitate cohesive resolution of this case. IV. PROPOSED SCHEDULE FOR COMPLETING DISCOVERY Current Date Proposed Date Amend Pleadings and Add Parties: June 13, 2023 Closed Initial Expert Disclosures: October 11, 2023 Closed Rebuttal Expert Disclosures: November 13, 2023 Remain the same Page 4 of 6 1 Close of Discovery: December 11, 2023 February 12, 20241 2 Dispositive Motions: January 09, 2024 April 8, 2024 3 Joint Pretrial Order: February 08, 2024 May 8, 2024 Based on the foregoing, the parties respectfully request this Court grant their 4 5 Stipulation and Order to Extend Discovery Deadlines (Second Request). 6 DATED November 20, 2023. DATED November 20, 2023. 7 PRINCE LAW GROUP LEWIS BRISBOIS BISGAARD & SMITH, LLP 8 /s/ Dennis M. Prince _______________________ DENNIS M. PRINCE Nevada Bar No. 5092 ANGELA M. LEE Nevada Bar No. 14905 10801 W. Charleston Blvd., Suite 560 Las Vegas, NV 89148 Attorneys for Plaintiff 9 10 11 12 13 14 /s/ Michael Smith ________________________ DARRELL D. DENNIS Nevada Bar No. 6618 MICHAEL R. SMITH Nevada Bar No. 12641 6385 S. Rainbow Blvd. Ste. 600 Las Vegas, NV 89118 Attorneys for Defendants 15 ORDER 16 IT IS SO ORDERED. 17 18 1. The discovery cut-off shall be February 12, 2024. 19 2. Amending the Pleadings and Adding Parties. The last date for filing motions to 20 amend pleadings or to add parties shall not be later than 90 days prior to the close of 21 discovery. In this action, the last date to file motions to amend the pleadings or add 22 parties has Closed. 23 3. 24 shall be 60 days before the discovery cut-off date. In this action, the last date to disclose 25 experts has Closed. The date for the disclosure of rebuttal expert witnesses shall be 30 26 days after the initial disclosure of experts. In this action, the last date to disclose rebuttal FRCP 26(a)(2) Disclosures (Experts). The last day to disclose expert witnesses 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 1 The actual date falls on Sunday, February 11, 2024. Page 5 of 6 1 experts shall remain the same November 13, 2023. 2 4. 3 than 30 days after the discovery cut-off date. In this action, the last date to file 4 dispositive motions shall be April 8, 2024. 5 5. 6 days after the date set for filing dispositive motions. In this action, the joint pretrial 7 order shall be filed on or before May 8, 2024. 8 6. 9 objections thereto shall be included in the Joint Pretrial Order. Dispositive Motions. The last date to file dispositive motions shall not be later Joint Pretrial Order. The Joint Pretrial Order shall be filed no later than 30 FRCP 26(a)(3) Disclosures. The disclosures required by FRCP 26(a)(3) and any 10 11 12 11/21/2023 DATED: _______________________________ 13 14 15 _______________________________________ UNITED STATES MAGISTRATE JUDGE 16 17 18 19 20 21 22 23 24 25 26 27 28 10801 W. Charleston Blvd. Suite 560 Las Vegas, NV 89135 Page 6 of 6
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