United States District Court, D. Nevada
DOUGLAS S. GOLD, an individual, Plaintiff,
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
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:
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.
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.
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.
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.
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.
parties agreed to continue the September 4, 2019 mediation
approximately 30 days.
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.
Defendant agrees and stipulates to have a live person with
settlement authority on behalf of Defendant present at the
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.
applicable discovery deadlines prior to the current stay of
discovery are as follows:
Amend pleadings/Add Parties:
June 13, 2019
July 12, 2019
Interim Status Report:
July 12, 2019
Rebuttal Expert Designations:
August 13, 2019
September 11, 2019
October 11, 2019
Joint Pre-Trial Order:
November 12, 2019