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Jaragosky v. Ford Motor Co.

United States District Court, D. Nevada

March 30, 2018

RONALD R. JARAGOSKY, a single man, Plaintiff,
v.
FORD MOTOR COMPANY, a Delaware corporation; and JOHN DOE ENTITIES I-X, inclusive, Defendants.

          SNELL & WILMER L.L.P. JOSHUA D. COOLS ATTORNEYS FOR DEFENDANT FORD MOTOR COMPANY

          LAW OFFICES OF LYNN SHUMWAY BY G. LYNN SHUMWAY CORY M. JONES JONES WILSON, LLP BRENT GHELFI GHELFI LAW GROUP, PLLC ATTORNEYS FOR PLAINTIFF RONALD R. JARAGOSKY

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE DATES (SECOND REQUEST)

         Plaintiff Ronald R. Jaragosky and Defendant Ford Motor Company, hereby stipulate and agree to continue discovery in this matter by approximately 60 days.

         I. BACKGROUND

         This is a complicated product liability action arising from a motor vehicle collision involving a 2001 Ford Explorer and a 2012 Chrysler van. On December 20, 2015, Plaintiff Ronald Jaragosky was riding in the front passenger seat of the 2001 Ford Explorer. The Explorer was driven by non-party Judy Ann Jiworsky northbound on SR-160 in Pahrump, Nevada. As the Explorer approached the intersection of SR-160 and Matthew Lane, the 2012 Chrysler van turned left in front of the Explorer. The right front of the Explorer collided with right front of the Chrysler van. Mr. Jaragosky sustained significant injuries in the crash.

         On August 1, 2017 Plaintiff filed suit against Ford. Plaintiff alleges claims of negligence and strict product liability and seeks punitive damages. Plaintiff alleges that the 2001 Ford Explorer failed to adequately protect Plaintiff when the airbags did not deploy. Ford denies that the 2001 Ford Explorer was defective or that they are liable for Plaintiffs injuries and damages.

         II. REASON FOR DISCOVERY REQUEST

         The parties have diligently pursued discovery in this case. As previously reported to the Court, they had some initial difficulty obtaining the most recent medical records for Plaintiff from the California facilities where Plaintiff is currently residing. Plaintiff is essentially a quadriplegic and requires assistance in most of his activities of daily living. An administrator for Plaintiffs current facility was preventing Plaintiff from executing medical records authorizations which delayed the requesting of his most recent medical records. Plaintiff had to subpoena these records. The parties have now had the opportunity to get most of these documents.

         Additionally, after reviewing Ford's production of responsive documents to Plaintiffs written discovery requests, Plaintiff has identified additional documents that he needs prior to expert disclosures. Ford is working on locating and producing those additional documents, but will not be able to do so before the current deadline for Plaintiffs initial expert disclosures. The parties only recently determined that these documents would not be able to be produced prior to the expert disclosure deadlines. For this reason, the parties agree that it will be best to extend all discovery deadlines by 60 days to allow for the remaining written discovery to be completed prior to expert discovery in this case. The parties represent that good cause exists for this extension and that extending the expert deadline within the 21 day period set by LR 26-4 is due to excusable neglect, as set forth herein.

         III. DISCOVERY STATUS

         The following discovery has been completed:

• October 10, 2017 - Plaintiffs Initial Disclosure Statement
• November 10, 2017 - Ford Motor Company's Initial Disclosure Statement
• January 12, 2018 - Plaintiffs First Set of Non-Uniform Interrogatories to Defendant Ford Motor Company
• January 12, 2018 - Plaintiffs First Set of Requests to Produce to Defendant Ford Motor Company
• January 26, 2018 - Ford Motor Company's First Request for Production of Documents to Ronald R Jaragosky
• January 26, 2018 - Ford Motor Company's First Set of Non-Uniform Interrogatories ...

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