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Gold v. Jewison

United States District Court, D. Nevada

September 3, 2019

DOUGLAS S. GOLD, an individual, Plaintiff,
v.
PAUL A. JEWISON, an individual; DOES I - X; and ROE CORPORATIONS I - X, inclusive, Defendants.

          PHILLIP R. EMERSON, ESQ. EMERSON LAW GROUP Attorney for Defendant, PAUL A. JEWISON

          STIPULATION AND ORDER TO EXTEND STAY OF DISCOVERY PENDING MEDIATION

         Defendant, PAUL A. JEWISON, by and through his counsel of record, and Plaintiff, DOUGLAS S. GOLD, by and through his counsel of record, stipulate as follows:

         1. This case arises from a jet ski accident that occurred on August 28, 2016 in Dana Point, California. Plaintiff was operating a SeaDoo GTI watercraft, in or about the area of Dana Point, California. At or about that same date and time, Defendant was also operating a SeaDoo GTI watercraft, in or about the area of Dana Point, California. Plaintiff alleges that Defendant operated his watercraft in an unsafe and unreasonable manner, so as to cause his watercraft to strike Plaintiff's watercraft with great force, which Plaintiff alleges caused him significant and substantial damages.

         2. This matter has been extensively litigated. Discovery completed to date include completed written discovery requests, depositions of both parties, as well as the Independent Medical Examination of Plaintiff.

         3. To date, the parties have not engaged in any form of alternative dispute resolution or otherwise shared meaningful settlement discussions. However, both parties agree that the case has reached a juncture in which substantive settlement discussion may result in the complete resolution of the case. To that end, the parties previously agreed to and scheduled a private mediation with Gregory T. Hafen on September 4, 2019. Neither party committed that a settlement would be reached, but both parties attested that they would enter into and participate in the mediation in good faith and with sincere efforts to reach an agreement to resolve the case.

         4. On August 26, 2019, Plaintiff served Plaintiff Douglas S. Gold's Second Supplemental Federal Rule of Civil Procedure 26(A) Disclosure Statement. This disclosure included nearly 300 pages of medical and billing records as well as an additional $87, 185.63 in claimed damages.

         5. Due to the significant nature of this supplemental disclosure nine days before the scheduled mediation, Defense counsel requested an additional thirty (30) days to review and evaluate the newly disclosed information before engaging in meaningful settlement negotiations based on the amount of Plaintiff's claimed damages therein.

         6. The parties agreed to continue the September 4, 2019 mediation approximately 30 days.

         7. The parties have agreed to and scheduled an updated date for the private mediation with Gregory T. Hafen on October 2, 2019. The parties cannot commit that a settlement would be reached, but attest that they will enter into and participate in the mediation in good faith and with sincere efforts to reach an agreement to resolve the case.

         8. Defendant agrees and stipulates to have a live person with settlement authority on behalf of Defendant present at the above-mentioned mediation.

         9. To save the parties from the need to invest resources in form of experts and other additional necessary discovery if the case does not settle, the parties stipulate to extend the stay all proceedings in this case pending the completion of mediation in this case.

         10. The applicable discovery deadlines prior to the current stay of discovery are as follows:

Amend pleadings/Add Parties:

June 13, 2019

Initial Experts:

July 12, 2019

Interim Status Report:

July 12, 2019

Rebuttal Expert Designations:

August 13, 2019

Discovery Cutoff:

September 11, 2019

Dispositive Motions:

October 11, 2019

Joint Pre-Trial Order:

November 12, 2019


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