Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Morimoto v. Whitley

United States District Court, D. Nevada

February 15, 2018

Bernadine Morimoto, as Personal Representative of the ESTATE OF ABGYGAILE B., deceased; EMBER B., a minor, by and through maternal grandmother and legal guardian, Bernadine Morimoto; and KARRIAH M., a minor, by and through maternal grandmother and legal guardian, Bernadine Morimoto, Plaintiffs,
v.
RICHARD WHITLEY, Director of the Nevada Department of Health and Human Services; KELLY WOOLRIDGE, Administrator of the Nevada Division of Child and Family Services; DONALD BURNETTE, Clark County Manager; CLARK COUNTY; TIMOTHY BURCH, Director of Clark County Department of Family Services; JAMES HARDEE, individually; HOPELINK OF SOUTHERN NEVADA, a Nevada Non-Profit Corporation; SHERRY BENNETT, individually; JUSTIN TOM BENNETT, individually; DOES I-X, inclusive; ROES XI-XX, inclusive; Defendants.

          CHRISTIANSEN LAW OFFICES, PETER S. CHRISTIANSEN, ESQ. Nevada Bar No. 5254 R. TODD TERRY, ESQ. Nevada Bar No. 6519 WHITNEY J. BARRETT, ESQ. NV Bar No. 13662 Attorneys for Plaintiffs

          SKANE WILCOX LLP, DANIELLE A. KOLKOSKI, ESQ. NV Bar No. 8506 Attorneys for Defendants Hopelink of Southern Nevada and James Hardee

          OLSON, CANNON, GORMLEY, ANGULO & STOBERSKI, FELICIA GALATI, ESQ. NV Bar No. 7341 Attorneys for Defendants Clark County, Donald Burnette and Timothy Burch

          STIPULATION TO MODIFY SCHEDULING ORDER DEADLINES (1ST REQUEST)

         This Stipulation to modify the scheduling order is entered into by and between Plaintiff BERNADINE MORIMOTO, as Personal Representative of the Estate of Abygaile B. and legal guardian and maternal grandmother of Ember B. and Karriah M.; and Defendants RICHARD WHITLEY; KELLY WOOLRIDGE; DONALD BURNETTE; CLARK COUTNY; TIMOTHY BURCH; JAMES HARDEE; and HOPELINK OF SOUTHERN NEVADA, by and through their attorneys of record, pursuant to LR IA 6-1 and LR 26-4 and based upon the following. This is the first request for an extension of the discovery deadlines.

         (a) A STATEMENT OF DISCOVERY COMPLETED TO DATE:

         Plaintiffs, Richard Whitley and Kelly Wooldridge ("State Defendants"), Clark County, James Hardee, and Hopelink have exchanged initial disclosures of documents and the names of individuals with knowledge of the facts pertaining to Plaintiffs' claims against Defendants. Clark County has propounded written discovery requests to Plaintiffs, including interrogatories, requests for production and requests for admission. Plaintiffs' responses are due on February 27, 2018. Plaintiffs have propounded written discovery requests to Defendants Hopelink, Frank Hardee and Clark County, including interrogatories and requests for production. James Hardee's and Hopelink's responses were due on February 9, 2018 and Clark County's responses were due on February 12, 2018.

         (b) A SPECIFIC DESCRIPTION OF THE DISCOVERY THAT REMAINS TO BE COMPLETED:

         (1) Defendants anticipate taking the deposition of Bernadine Morimoto;

         (2) Plaintiffs anticipate taking the depositions of Defendants James Hardee; Karen Kyger; the 30(b)(6) witness for Hopelink of Southern Nevada; 30(b)(6) witness for Clark County; Timothy Burch; Donald Burnette; Richard Whitley; and Kelly Woolridge;

         (3) Subpoenas to Las Vegas Metropolitan Police Department;

         (4) Disclosure of expert witnesses;

         (5) Depositions of the parties' expert witnesses;

         (6) Additional document production

         (c) THE REASON WHY DISCOVERY REMAINING WAS NOT COMPLETED WITHIN THE TIME ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.