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Wysocki v. Dourian

United States District Court, D. Nevada

December 29, 2017

DALE WYSOCKI, individually and as Executor of the Estate MICHAEL WYSOCKI, Plaintiffs,
v.
DIKRAN DOURIAN, individually, DOE INDIVUDUALS I through X, inclusive and ROE ENTITIES I through X, inclusive, Defendant.

          COLQUITT & ABBATANGELO, LTD. Ronald A. Colquitt, Esq. Attorney for Plaintiff.

          MORRIS SULLIVAN LEMKUL & PITEGOFF, LLP. Christopher A. Turtzo, Esq. Jennifer Saccuzzo, Esq. Attorneys for Defendant Dikran Dourian.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (FIRST REQUEST)

         The parties hereto, by and through the undersigned counsel of record, stipulate, agree and make this joint application to extend the discovery deadlines in this matter for a period of sixty (60) days up to and including Thursday, April 12, 2018. The present discovery cut-off date is Monday, February 12, 2018. The reason for this request is as follows:

         The parties are attempting to negotiate a potential resolution which would completely dispose of all claims in this case; however, the parties need additional time to address and resolve any potential issue regarding Medicare payments and secondary payor liens. The parties expect that it may take up to 60 days to receive a response from Medicare.

         Also, on December 15, 2017, the Defendant finally obtained more than 2, 000 pages of critical records from University Medical Center. Defendant has diligently sought these records for nearly six months. If the parties cannot finalize a resolution, Defendant's expert requires approximately two additional weeks to review complete an expert report based on these records.

         For the reason stated herein, the parties respectfully request that the Court permit an extension of the discovery deadlines set forth in the current stipulated and ordered discovery plan [Doc. 31] as outlined below.

         In regard to the status of the case, to date the parties have completed the following:

1. Complaint filed in District court A-16-743152-C on 9/08/16;
2. Petition for Removal to Federal Court, filed 02/02/17;
3. Answer to Complaint, filed 02/09/17;
4. Joint Status Report, filed 03/02/17;
5. Discovery Plan/Scheduling Order, filed 03/27/17;
6. Stipulated Protective Order, filed 11/17/17;
7. Stipulated Discovery Plan/Scheduling Order, filed ...

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