United States District Court, D. Nevada
PADDA LAW, PLLC PAUL PADDA, ESQ. ATTORNEY FOR PLAINTIFF
ELIESON UNITED STATES ATTORNEY
M. ROBERTS ASSISTANT UNITED STATES ATTORNEY ATTORNEYS FOR THE
JOINT STIPULATION TO EXTEND SCHEDULING ORDER
to Local Rules 6-1, 26-4, and Fed.R.Civ.P. 6(b), the parties
stipulate, subject to this Court's approval, that the
deadlines in the approved discovery schedule be extended as
set forth below. The parties assert that good cause exists
for the requested extension.
Report. Discovery is currently set to close on
March 15, 2018. This request is made more
than 21 days prior to that cutoff date solely for the purpose
of extending the deadline to conduct depositions while the
parties are actively engaged in settlement
negotiations. The parties assert that good cause exists to
extend the deadline as set forth in Paragraph 4.
Additionally, should this stipulation be approved by the
Court, it will facilitate and increase the possibility of
resolution without the parties having to balance upcoming
deadlines. While the parties had previously represented that
they did not anticipate needing an additional extension,
Plaintiff's counsel was notified at the end of December
2017 that an office relocation he was intending to make had
to be postponed which will now affect his ability to devote
the time necessary to this and other case commitments. By
filing this stipulation jointly, the parties are in agreement
that this extension is warranted under the circumstances.
Status/Discovery Completed. The parties
have completed the following discovery:
• Initial and supplemental disclosures pursuant to
• Exchanged written discovery.
• Exchanged expert witness disclosures.
• Taken depositions of fact witnesses.
Discovery remaining. The only outstanding
discovery is depositions of expert witnesses (one in
California and one in Virginia) and some of Plaintiff's
treating physicians and health care providers, all of whom
are/were employed by Defendant. This additional discovery
that remains will require out-of-town travel and additional
coordination of schedules.
Reasons for extension. The parties request
this extension to provide them with the time to facilitate
potential resolution of the matter. The parties are actively
engaged in settlement negotiations and both parties are
hopeful that a resolution can be reached in the near future.
The parties continue to negotiate in good faith and request
this extension to avoid costly expert depositions and the
travel costs associated therewith.
course, if the parties are not able to reach a resolution,
they will need sufficient time to complete discovery. Given
the travel involved and the coordination of schedules
(including those of experts who have medical practices)
additional time is needed to provide enough time to complete
discovery while the parties continue the dialogue regarding
settlement. In addition to the foregoing, counsel for
Plaintiff had anticipated making an office relocation (after
being located approximately 6 years in his current location)
in early January 2018. However, in late December 2017, after
the parties filed the last extension request, he was notified
by the management of the building to which he is relocating
that the office move would need to be postponed until
mid-February 2018. The anticipated move to new offices has
required him to make a number of arrangements that are
disruptive to his law practice and which will continue to be
disruptive now that the relocation date has been postponed.
Upon relocation, Plaintiff's counsel will need time to
adjust to the new office (including implementing computer
support and related matters) while balancing numerous case
commitments in state and federal court.
of these reasons, the parties are in agreement that an
additional 90-day extension of the discovery ...