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Dixon v. Legacy Transportation Systems, LLC

United States District Court, D. Nevada

July 14, 2017

SARAH DIXON, Plaintiff,
v.
LEGACY TRANSPORTATION SYSTEMS, LLC; a Utah Limited Liability Company; ANGELES TRANSPORTATION, LLC; a Utah Limited Liability Company, LEONCIO ANGELES; Defendants.

          HALL JAFFE & CLAYTON, LLP, STEVEN T. JAFFE, ESQ., JASON R. WIGG, ESQ. ATTORNEYS FOR DEFENDANTS/THIRD-PARTY PLAINTIFFS LEGACY TRANSPORTATION SYSTEMS, LLC, ANGELES TRANSPORTATION, LLC & LEONCIO ANGELES

          DEFENDANTS'/THIRD-PARTY PLAINTIFFS' EMERGENCY MOTION TO CONTINUE HEARING OF ECF 101, 102, 109, AND 120 AND REQUEST FOR SANCTIONS

          Peggy A. Leen United States Magistrate Judge

         Defendants LEGACY TRANSPORTATION SYSTEMS, LLC; ANGELES TRANSPORTATION, LLC; and LEONCIO ANGELES (hereinafter collectively, the "Legacy Defendants"), by and through their counsel of record, Steven T. Jaffe, Esq., and Jason R. Wigg, Esq., of Hall, Jaffe & Clayton, LLP, hereby move on an emergency basis to continue the hearing as to ECF 101, 102, 109, and 120, and for sanctions.

         MEMORANDUM OF POINTS AND AUTHORITIES

         The Legacy Defendants have pending four motions set to be heard by this court on July 25, 2017. Counsel for the Legacy Defendants previously contacted the court about continuing the hearing date, because lead counsel for the Legacy Defendants, Steven T. Jaffe, Esq., will be away on a vacation between July 20 and August 2, which has been planned, booked, and paid for quite some time ago. See Jaffe Declaration, attached as Exhibit 1. The Court learned of the parties agreement to continue the July 25 hearing date in Legacy Defendants' Emergency Motion to Stay or Extend Briefing Deadlines [ECF No. 114] See Wigg Declaration, attached as Exhibit 2. Subsequent, good faith efforts were made to continue the hearing of the pending Motions to August 8. See Exhibits 1, 2, 3, 4, 5 and 6.

         The motions set for hearing are, as follows:

1. Motion to Strike Plaintiffs Expert, Dr. Kathleen Smith's Supplemental Report, ECF 101;
2. Motion to Strike Plaintiffs expert, Dan Berkabile, ECF 102;
3. Motion to Preclude Testimony from Plaintiffs treating physicians and to preclude them from offering expert testimony, ECF 109; and,
4. Motion to Preclude Dr. Kathleen Smith from testifying; or, Alternatively, to Order an Evidentiary Hearing, ECF 120.

         The Legacy Defendants have requested that Mr. Jaffe argue these four motions, as lead trial counsel expressly hired for that purpose in this matter.

         The Legacy Defendants began trying to obtain this rescheduling since June 23. See Exhibit 2. Since then, Jason R. Wigg, Esq., also working on this matter with Mr. Jaffe, obtained every party's consent. Id. Unfortunately, thereafter, counsel for the Plaintiff began stonewalling the process. Id., see also Exhibit 3 and 4, which includes true and correct copies of a series of emails exchanged between the parties on July 11 and July 12, respectively, regarding this matter. Specifically, Eric Dobberstein, Esq., Plaintiffs counsel, refused to commit to a date or provide alternative dates. Id. That conduct continued through July 12, 2017, without resolution. Emails and records confirm the following chronology:

June 13, 2017: The court ordered hearings on ECF 101, 102, and 109 on July 25, 2017, see ECF 112;
July 11, 2017: The court ordered an addition hearing on ECF 120, also to take place on July ...

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