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Bundy v. Las Vegas Valley Water District

United States District Court, D. Nevada

July 10, 2018

LINDA BUNDY, Plaintiff,
v.
LAS VEGAS VALLEY WATER DISTRICT, DOE INDIVIDUALS I through X, inclusive; and ROE CORPORATIONS I through X inclusive; Defendant.

          CALLISTER & ASSOCIATES Matthew Q. Callister, Esq. Nevada Bar No. 001396 Mitchell S. Bisson, Esq. Nevada Bar No. 011920 Attorneys for Plaintiff Linda Bundy

          WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP Sheri M. Thome, Esq. Nevada Bar No. 008657 I-Che Lai, Esq. Nevada Bar No. 012247 Attorneys for Defendant Las Vegas Valley Water District

          STIPULATION FOR EXTENSION OF DISCOVERY DEADLINES (FIRST REQUEST)

         The above named parties, by and through their respective counsel of record, hereby submit the following Stipulation for Extension of Discovery Deadline (First Request). This is the first stipulation for extension of discovery deadlines in this case.

         This request includes extensions of all pending pre-trial deadlines, including deadlines for initial expert and rebuttal expert disclosures under Rule 26(f)(3) and LR 26-1, dispositive motions, the interim status report, and joint pretrial order. The present and proposed new dates for these deadlines are set forth in Section D below. The extension is necessary to accommodate LVVWD's request for documents from third parties pertaining to damages and the parties' review of the documents pertaining to damages alleged in this case.

         A. DISCOVERY COMPLETED TO DATE

         On March 26, 2018, the parties held a Rule 26(f) conference. The proposed Discovery Plan and Scheduling Order was filed on April 16, 2018 and approved by this Court on the same day. After the court's approval of the Discovery Plan and Scheduling Order, the parties both served their respective initial Rule 26(a)(1) disclosures on April 20, 2018.

         On April 17, 2018, LVVWD served Plaintiff with interrogatories and requests for production. Plaintiff served her responses to the interrogatories on June 4, 2018 and her responses to the requests for production on June 6, 2018. Based on her responses, on June 20, 2018, LVVWD served requests on third parties for Plaintiff's employment and medical. On June 25, 2018, LVVWD served requests on the IRS for Plaintiff's tax records.

         B. DISCOVERY THAT REMAINS TO BE COMPLETED

         LVVWD has yet to receive the requested medical, employment, and tax records. Based on those records, the parties will need to determine the need to disclose any experts. Lastly, the parties will need to complete the deposition of Plaintiff, LVVWD's Rule 30(b)(6) designee and employees with knowledge of Plaintiff's employment, and experts. Depending on the information obtained during discovery, the parties may propound additional written discovery, serve additional document subpoenas, and depose additional witnesses.

         C. REASONS WHY DISCOVERY HAS NOT BEEN COMPLETED

         With the July 2, 2018 initial expert disclosure deadline less than a week away, the parties are not able to disclose an expert under that deadline. The requested medical, employment, and tax records pertain to Plaintiff's damages and are instrumental to the parties' determination of whether a damages expert is warranted. It is uncertain whether the parties would obtain those documents before July 2, 2018. If those documents arrive before July 2, 2018, it is uncertain whether any experts can review those records and provide an opinion in time.

         The parties did not request the instant extension sooner than 21 days before the current initial expert disclosure deadlines as the parties did not realize until recently that there was a need to obtain the third-party records prior to consulting with and disclosing an expert on damages. Good cause therefore justifies a short extension.

         Accordingly, the parties request that the court extend the discovery deadlines by 30 days to allow sufficient time for the parties to obtain and review third-party records pertaining to Plaintiff's damages and to determine the need for any expert disclosure.

         D. PROPOSED ...


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