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Momox-Caselis v. Juarez-Paez

United States District Court, D. Nevada

October 12, 2017

SERGIO MOMOX-CASELIS, MARIA MOMOX-CASELIS; NICOLASA HERNANDEZ, as Special Administrator of the estate of M.M., born May 15, 2013 and died October 12, 2014, Plaintiffs,
v.
MAIRA JUAREZ-PAEZ; LISA RUIZ-LEE; KIM KALLAS; TARA DONOHUE; BETH ANN NELSON; JEREMY LAW; IRENE KOZIKI, SHUUANDY ALVAREZ, individuals; Estate of JOAQUIN JUAREZ-PAEZ; DOE individuals I-X; ROE CLARK COUNTY DEPARTMENT OF FAMILY SERVICES EMPLOYEES; XI-XX, individually and in their official capacities; CLARK COUNTY DEPARTMENT OF FAMILY SERVICES; COUNTY OF CLARK, a political subdivision of the State of Nevada; and ZOE CORPORATIONS XXI-XXX, Defendants.

          FELICIA GALATI, ESQ. Nevada Bar No. 7341 OLSON, CANNON, GORMLEY ANGULO & STOBERSKI Attorneys for Defendants COUNTY OF CLARK, CLARK COUNTY DEPARTMENT OF FAMILY SERVICES, TARA DONOHUE, LISA RUIZ-LEE, KIM KALLAS, BETH ANN NELSON, JEREMY LAW, IRENE KOZIKI, and SHUUANDY ALVAREZ.

          MARJORIE HAUF, ESQ. ADAM GANZ, ESQ. Attorneys for Plaintiffs.

          ERRATA TO STIPULATION AND ORDER TO EXTEND DISCOVERY (#101) (FOURTH REQUEST)

         Pursuant to FRCP 6 and FRCP 26, the parties, by and through their respective counsel of record, hereby submit this errata because they inadvertently forgot to include a request to extend the discovery cut-off date, which is necessary because they are requesting other dates that come before that date be extended. The parties stipulate and agree to jointly move this Court for an Order to extend the discovery deadlines, as set forth below.

1. Extend the date to disclose rebuttal expert witnesses from 10/20/17 to 12/4/17
2. Extend the discovery cut-off deadline from 11/20/17 to 1/4/2018
3. Extend the date to file dispositive motions from 12/20/17 to 2/5/18 4. Extend the date to file the Joint Pre-Trial Order from 1/18/18 to 3/4/18 5. Extend the date to file Pre-Trial Disclosures or objections to the Pre-Trial Order from 2/19/18 to 4/3/18.

         I. DISCOVERY COMPLETED

         Defendants COUNTY OF CLARK, CLARK COUNTY DEPARTMENT OF FAMILY SERVICES, TARA DONOHUE, LISA RUIZ-LEE, KIM KALLAS, BETH ANN NELSON, JEREMY LAW, IRENE KOZIKI, and SHUUANDY ALVAREZ (“Defendants”) provided their initial witness and document disclosures pursuant to FRCP 26(a)(1) on April 19, 2016, and have since provided 15 supplemental disclosures. To date, Defendants have disclosed thousands of pages of documents. Plaintiffs provided their initial witness and document disclosures pursuant to FRCP 26(a)(1) on April 15, 2016.

         Defendants propounded written discovery (interrogatories, requests for production and requests for admission) to Plaintiffs SERGIO MOMOX-CASELIS, MARIA MOMOX-CASELIS and NICOLASA HERNANDEZ (“Plaintiffs”) and Plaintiffs responded thereto.

         Plaintiffs propounded written discovery (interrogatories, requests for production and requests for admission) to Defendants, and Defendants responded thereto.

         The following depositions have been taken to Dated: Kim Kallas, Patricia Meyers, Maria Juarez-Paez, Shuuandy Alvarez, Lani Aitken and Oscar Benavides.

         Plaintiffs have disclosed their initial expert witnesses in accordance with FRCP 26(a)(2).

         II. GROUNDS FOR DISCOVERY EXTENSION:

         This case is complicated due to the number of parties and the circumstances of this case, including the fact that there are two sets of foster parents relevant to and that are parties in this action. As such, there are twice as many documents to disclose and many more depositions that will need to be taken. While Defendants have produced the most of their documents in this case, they still have additional documents to produce that need to be reviewed and redacted as to other minors, including pursuant to their obligations under NRS 432B.280 ...


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