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Momox-Lis v. Juarez-Paez

United States District Court, D. Nevada

November 28, 2017

SERGIO MOMOX-LIS, individually and as Guardian Ad Litem for MARIA MOMOX-LIS; 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 DONAHUE; PATRICIA MEYERS; JEREMY LAW; IRENE KOZIKI; SHUUANDY ALVAREZ; LANI AITKEN; OSCAR BENEVIDES, individuals; Estate of JOAQUIN JUAREZ-PAEZ; DOE individuals I-X; ROE CLARK COUNTY DEPARTMENT OF FAMILY SERVICES EMPLOYEES XIII-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.

          GANZ & HAUF MARJORIE HAUF, ESQ. Attorneys for Plaintiffs

          OLSON, CANNON, GORMLEY ANGULO & STOBERSKI WALTER R. CANNON, ESQ., FELICIA GALATI, ESQ., Attorneys for Defendants COUNTY OF CLARK, TARA DONOHUE, LISA RUIZ-LEE, KIM KALLAS, PATRICIA MEYERS, JEREMY LAW, IRENE KOZICKI, SHUUANDY ALVAREZ, LANI AITKEN AND OSCAR BENAVIDES

          STIPULATION AND ORDER TO EXTEND DISCOVERY (FIFTH REQUEST)

         Pursuant to FRCP 6 and FRCP 26, the parties, by and through their respective counsel of record, hereby 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 12/4/17 to 1/31/18
2. Extend the discovery cut-off deadline from 1/4/2018 to 3/2/18
3. Extend the date to file dispositive motions from 2/5/18 to 4/3/18
4. Extend the date to file the Joint Pre-Trial Order from 3/4/18 to 4/30/18
5. Extend the date to file Pre-Trial Disclosures or objections to the Pre-Trial Order from 4/3/2018 to 6/27/18

         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 ...


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