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Kuklock v. State ex rel. Department of Transportation

United States District Court, D. Nevada

November 25, 2019

JENNIFER KUKLOCK, Plaintiff,
v.
STATE OF NEVADA, ex rel. its DEPARTMENT OF TRANSPORTATION, Defendant.

          AARON D. FORD Attorney General Deputy Attorney General Kevin A, Pick Senior Deputy Attorney General Attorneys fir Defendant.

          BENSON LAW, LLC Kevin Benson, Esq., Attorneys for Plaintiff.

          AMENDED STIPULATED DISCOVERY PLAN SPECIAL SCHEDULING REVIEW REQUESTED

         The parties' counsel held the Fed.R.Civ.P. 26(f) meeting on August 29, 2019 and met and conferred on November 18, 2019 regarding extending the deadlines in the original scheduling order. The parties, by and through their respective undersigned counsel jointly submit the following amended stipulated discovery plan and scheduling order, pursuant to LR 26-1.

         Amended Discovery Plan and Schedule

         Date first defendant answered or otherwise appeared: July 30, 2019.

         Initial Disclosures:

         Pursuant to Federal Rule of Civil Procedure 26(f) and Local Rule 26-1 (a), Hie parties submitted their initial disclosures on or about September 12, 2019.

         The parties are engaged in efforts at early resolution, but if: such efforts fail, the parties anticipate additional time for discovery will be required. The current deadline for expert disclosures is December 2, 2019, but the parties have not deposed any witnesses and have responded to the first round of: written discovery. Over 1000 pages of documents have been produced. Additionally, the state administrative process for contracting with expert witnesses takes a minimum of 30 days. NDOT has begun this process but will need more time. Additionally, NDOT anticipates noticing depositions of: multiple witnesses, and with the holidays approaching, scheduling is likely to be challenging. NDOT respectfully requests a six-month extension of: previously agreed upon deadlines, starting with the deadline for expert disclosures. In light of the state's administrative process related to retaining experts, NDOT requests that the deadline for rebuttal experts be 60 days after the initial disclosure of experts. Plaintiff does not object to NDOT's proposed amendments to the scheduling order.

         The parties propose the following changes to the original discovery plan (ECF No. 12):

Description

Original Deadline

Proposed Deadline

Discovery Cut-Off Date

Monday, January 27, 2020

Monday, July 27, 2020

Deadline to Amend Pleadings and Add Parties

Tuesday, October 29, 2019

Tuesday, October 29, 2019

Deadline to Disclose Experts

Monday, December 2, 2019

Monday, May 4, 2020

Deadline to Disclose Rebuttal Expert Disclosures

Thursday, January 2, 2019

Wednesday, July 8, 2020

Deadline to File dispositive Motions

Wednesday, February 26, 2020

Monday, August 27, 2020

Pretrial Order and Pretrial Disclosures

Friday, March 27, 2020 or 30 days after decision on dispositive motions

Monday, September 28, 2020 or 30 days after decision on 1 dispositive motions

         Alternative Dispute Resolution:

         The parties certify that they have met and conferred about the possibility of using alternative dispute-resolution processes including mediation, arbitration, and if applicable, early neutral evaluation. The parties participated in an early neutral evaluation on November 7, 2019.

         Alternative Forms of Case Disposition:

         The parties certify that they have considered consent to trial by a magistrate judge under 28 U.S.C. § 636(c) and Fed.R.Civ.P. 73 and the use of the Short Trial Program (General ...


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