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Bynum v. City of Las Vegas

United States District Court, D. Nevada

December 18, 2017

CHARLENE BYNUM individually, as the wife of RONALD BYNUM and as the Guardian of the Person and Estate of RONALD BYNUM, Plaintiff,
v.
CITY OF NORTH LAS VEGAS; JACOB RAY P#1886; RODRIGO DELARA P#2417; JOHN E. TONRY P#1684; JESSE LEE CESENA P#2425; ALEXANDER PEREZ, JEFREY K. LYTLE, CITY OF LAS VEGAS, MICHELLE FREEDMAN DOES 1-100 and DOE ENTITIES 1-10, Defendants.

          LAW OFFICE OF DAN M. WINDER, P.C DAN M. WINDER, ESQ. Nevada State Bar No. 1569 SCOTT C. DORMAN, ESQ. Nevada State Bar No. 13108 KRISTINA MILETOVIC, ESQ. Nevada State Bar No. 14089 Attorneys for Plaintiff

          BRADFORD R. JERBIC City Attorney Nevada Bar No. 1056 By: JOHNA.CURTAS Deputy City Attorney Nevada Bar No. 1841 Attorneys for Defendants City of Las Vegas and Michele Freeman

          LEWIS BRISBOIS BISGAARE & SMITH, LLP ROBERT W. FREEMAN, ESQ. Nevada State Bar No. 3062 NOEL E. EIDSMORE, ESQ. Nevada State Bar No. 7688 Attorneys for Defendants City of North Las Vegas, Officers Jacob Ray, Rodrigo Delara, John E. Tonry, Jesse Lee Cesena, Chief Alexander Perez, and Fire Chief Jeffrey K. Lytle

          STIPULATION AND ORDER TO AMEND DISCOVERY PLAN AND PROPOSED SCHEDULING ORDER (FRCP 26(F)(3) AND LR 26-L(B))

         The order signed previously prepared by counsel and signed by the court November 29, 2017, contains an error in the scheduling of the Rebuttal Expert Deadline making the disclosure of the Rebuttal Experts due before the Expert Disclosure Deadline. The proposed Amended Scheduling Order corrects the error.

         SPECIAL SCHEDULING REVIEW REQUESTED.

         The parties request that discovery run for 270 days from the date the first answer was filed. The first answer was filed September 7, 2017. This extension of time is necessary because many parties are yet unidentified and must be ascertained through discovery. The last answering defendant answered on September 26, 2017.

         1. Meeting:

         Pursuant to FRCP 26(f), a telephonic discovery meeting was held on Tuesday, November 7, 2017, at 2:00 P.M., and was attended by:

- Arnold Wienstock, Esq. of the Law Offices of Dan M. Winder, P.C., for Plaintiff,
- John A. Curtas, Deputy City Attorney, for Defendants City of Las Vegas and Michele Freeman, and
- Noel E. Eidsmore, Esq. of Lewis Brisbois Bisgaard & Smith, LLP, for Defendants City of North Las Vegas, Officers Jacob Ray, Rodrigo Delara, John E. Tonry, Jesse Lee Cesena, Chief Alexander Perez, and Fire Chief Jeffrey K. Lytle.

         2. Pre-Discovery Disclosures:

         Plaintiff and Defendants have until Tuesday, November 21, 2017 to provide their initial disclosures as required by FRCP 26(a), which is fourteen (14) days after the FRCP 26(f) meeting and includes the requested extension of 90 days.

         3. Discovery Plan: The parties jointly propose the Court ...


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