United States District Court, D. Nevada
ABC INDUSTRIAL LAUNDRY, LLC, a Nevada limited liability company, dba UNIVERSAL LAUNDRY and SUPPLY, Plaintiff,
FEDERAL INSURANCE COMPANY, et al., Defendants.
OFFICES OF STEVEN J. PARSONS Attorneys for Plaintiff ABC
INDUSTRIAL LAUNDRY, LLC
SILVESTRI JAMES P.C. SILVESTRI Attorneys for Defendant
FEDERAL INSURANCE COMPANY
HAMPTON, LLP CHRISTINE EMANUELSON by: WHITNEY WILCHER
Attorneys for Defendant NATIONWIDE MUTUAL INSURANCE CO.
STATUS REPORT; STIPULATED DISCOVERY PLAN AND PROPOSED
SCHEDULING ORDER (IN RESPONSE TO ORDER (DOC. NO. 60)
ABC INDUSTRIAL LAUNDRY, LLC, by its
attorneys, Steven J. Parsons of Law Office Of Steven J.
Parsons, and Joseph N. Mott and Scott Lundy of Rempfer Mott
Lundy, PLLC; Defendant FEDERAL INSURANCE
COMPANY, by its attorneys, James P.C. Silvestri and
Brian Goldman of Pyatt Silvestri, and Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY, by its attorneys, Christine Emanuelson and
Whitney Wilcher of Hines Hampton, LLP, hereby submit this
Status Report and Stipulated Discovery Plan and Proposed
Scheduling Order pursuant to the Court's Order of
December 21, 2017, regarding the parties' Status Check
(Doc. No. 60).
parties have met, conferred and agree that at present, the
following discovery remains outstanding:
(1) ABC's principals and employees, Ran Brisman, Avi
Cohen, and Jim Smail, as well as Fed. R. Civ. P., 30(b)(6)
(2) ABC's former principals and employees, Moshe Levy,
Yaakov "Kobi" Levy, and Yuda Levy;
(3) Rudi Moors, Christeyns' CEO (to be completed);
(4) Claims persons of each Defendant's claims operation,
as well as Fed. R. Civ. P., 30(b)(6) witnesses of each
(5) Rimkus Consulting Group, Inc.;
(6) Textile Solutions, LLC;
(7) Wynn Las Vegas, LLC;
(8) Brown & Brown Northwest;
(9) CHEM-BAC Laboratories, Inc;
(10) CR Systems Consulting;
(11) Frank Campagna, CPA; and
(11) The various experts as designated by the parties.
parties anticipate additional written discovery will follow
of the Companion Case
and incorporated herein as Exhibit 1 is an Order of the Hon.
Richard Scotti, District Judge, upon the Stipulation to
Extend Discovery Deadlines, Amend the Scheduling Order, and
Reset the Trial in the associated Eighth Judicial District
Court, Clark County, Nevada case ABC Industrial Laundry,
LLC v. Christeyns Laundry Technology, LLC; docketed in
that Court as No. A-15-720810-C. The attached exhibit shows
similar deadlines now set by that Court, as are requested in
this Discovery Plan and Scheduling Order.
DISCOVERY CUT-OFF Dated:
plan is in general accordance with LR 26-1(e)(1), and the
parties request two hundred seventy (270) days to conduct
percipient witness discovery measured from January 18, 2018,
the date of this Status Report. The last proposed day of
discovery of percipient witnesses shall be Monday, October
FED. R. CIV. P. 26(a)(2) DISCLOSURES (EXPERTS):
of experts shall proceed according to Fed.R.Civ.P. 26(a)(2)
i. The disclosure of experts and expert reports shall occur
on Tuesday, July 17, 2018, which is ninety (90) days before
the discovery cut-off date;
ii. The disclosure of rebuttal experts shall occur on
Thursday, August 16, 2018, which is thirty (30) days after
the disclosure of experts.
AMENDMENT OF THE PLEADINGS AND ADDING PARTIES:
parties shall have until Tuesday, July 17, 2018, to file any
motion to amend the pleadings or to add parties. This is
ninety (90) days before the discovery cut-off, which is in
accordance with LR 26-1(e)(2).