United States District Court, D. Nevada, Southern Division
Darrell D. Dennis, Esq. Steven B. Abbott, Esq. Blake A.
Doerr, Esq. LEWIS BRISBOIS BISGAARD & SMITH, LLP
Attorneys for Defendant, THE SIGNATURE CONDOMINIUMS, LLC
LAW FIRM JONATHAN T. REMMEL, ESQ. Attorney for Plaintiff,
PLAINTIFF DINA MAMUNES' MOTION TO EXTEND
Dina Mamunes (“Plaintiff”), by and through her
attorney, JONATHANT T. REMMEL, ESQ. of the REMMEL LAW FIRM,
hereby submits her Motion to Extend Discovery Deadlines. This
Motion will likely be unopposed as the parties were
discussing a stipulation to extend the discovery deadlines;
however, Defense Counsel left for personal vacation before
the Stipulation was formally agreed to, thereby requiring the
filing of this Motion to meet the 21 day deadline for filing.
This Motion is made pursuant to the provisions of Local Rule
26-4 which provides for an extension of discovery upon a
showing of good cause, and excusable neglect, present in
circumstances such as those at issue here. This is the first
request for an extension of discovery made in this case.
OF POINTS AND AUTHORITIES
discovery cut off in this matter is May 26, 2017. The current
deadline for initial expert disclosures is March 27, 2017.
Plaintiff resides in Colorado, along with a majority of her
treating physicians. To date, it has been difficult for the
parties to obtain records from these out-of-state medical
providers. Once the records are obtained, it will also be
necessary to submit the same to medical experts for review
and consideration. Once the records are secured, the parties
may also desire to set the depositions of these providers.
However, due existing trial schedules, vacations and other
calendaring conflicts, Plaintiff (and presumably the defense)
will likely be unable to meet the existing deadlines.
parties were able to confer on March 3, 2017 regarding the
issue, but were unable to formalize a stipulation regarding
this brief extension of discovery before Defense counsel left
for vacation. Notwithstanding, and in an abundance of
caution, Plaintiff submits this motion for a 60 day extension
of all discovery deadlines pursuant to FRCP l6(b)(4), FRCP 26
and Local Rule 26-4 in order to best ensure there is enough
time for both parties to adequately prepare for the pending
initial expert discovery deadline.
Discovery Conducted to Date
August 29, 2016, the parties conducted the Rule 26(f)
meeting. The parties have exchanged initial and (several)
supplemental Rule 26 disclosures. Each party has propounded
initial written discovery requests-- including
interrogatories, request to produce, and request for
admissions. The parties have conducted a site inspection,
along with non-destructive testing. The Defendant has taken
the deposition of Plaintiff.
to be completed includes:
• Deposition of remaining fact witnesses;
• Deposition of defendants' Rule 30(b)(6) ...