United States District Court, D. Nevada
DALE WYSOCKI, individually and as Executor of the Estate MICHAEL WYSOCKI, Plaintiffs,
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.
SULLIVAN LEMKUL & PITEGOFF, LLP. Christopher A. Turtzo,
Esq. Jennifer Saccuzzo, Esq. Attorneys for Defendant Dikran
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES
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:
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.
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
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.
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
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