United States District Court, D. Nevada
LVC SURGICAL CENTER, LLC, a Nevada Limited Liability Corporation; Plaintiff,
INSIGHT SURGICAL EQUIPMENT CO., an Arizona Corporation; DOES 1 through 10, inclusive; and ROE BUSINESS ENTITIES I through X, inclusive, Defendant.
MICHAEL B. LEE. P.C. MICHAEL B. LEE MICHAEL N. MATTHIS
Counsel for Plaintiff
ELSER Chris Richardson MICHAEL P. LOWRY, ESQ., CHRISTOPHER J.
RICHARDSON, ESQ. Attorneys for Insight Surgical Equipment Co.
[PROPOSED] JOINT DISCOVERY PLAN AND SCHEDULING ORDER
(FED. R. CIV. P. 26(F)) SUBMITTED IN COMPLIANCE WITH LR
WEKSLER UNITED STATES MAGISTRATE JUDGE
to Federal Rule of Civil Procedure 26(f) and Local Rule
26-1-1, Plaintiff LVC SURGICAL CENTER, LLC
(“Plaintiff”, “Counter-Defendant”, or
“LVC”), by and through its attorneys of record,
the law firm of Michael B. Lee., P.C., and Defendant INSIGHT
SURGICAL EQUIPMENT CO. (“Insight”,
“Defendant”, or (“Counterclaimant”),
by and through its counsel of record, Wilson Elser,
(collectively the “Parties”), hereby submit to
this Honorable Court the following joint discovery plan and
Meeting. As required by this Honorable Court by way of an
Order (ECF No. 021), Michael B. Lee, counsel for Plaintiff,
and Christopher Richardson, counsel for Defendant, met and
conferred on November 13, 2019, to develop the following
discovery plan. The Complaint was originally filed in Clark
County, Nevada. Defendant removed it (ECF No. 1) October 4,
Pre-Discovery Disclosures. Plaintiff disclosed its initial
disclosures of its witnesses, documents, damages, and no
insurance on November 13, 2019. Insight will exchange the
information as required by Federal Rule of Civil Procedure
26(a)(1) on or before November 27, 2019.
Discovery Plan. All discovery in this case will be conducted
in accordance with the Federal Rules of Civil Procedure, and
discovery will encompass issues commonly pursued in breach of
contract, deceptive trade practices cases. The parties
propose the following discovery overview, discovery plan and
a. Discovery Cut-off Date. Plaintiff filed the instant action
in the Nevada District Court, Eighth Judicial District Court,
on September 11, 2019. Defendants filed an Answer and
Counterclaim on November 6, 2019 (ECF No. 021). Plaintiff
filed a Reply to the Counterclaims on November 6, 2019 (ECF
b. The Parties propose the following discovery dates:
i. Discovery Cut-Off by May 11, 2020.
ii. Joint Protective Order by February 11, 2020.
iii. Last date to amend pleadings and add parties by Feb. 11,
iv. Last date to file interim status report by March 12,
v. Last date to disclose experts pursuant to Fed.R.Civ.P.