Filed: Feb. 17, 2016
Latest Update: Feb. 17, 2016
Summary: SUPPLEMENTAL JOINT CASE MANAGEMENT REPORT VALERIE P. COOKE , Magistrate Judge . COMES NOW Defendant, CMH Homes, Inc. ("CMH"), by and through its attorneys of record, ALVERSON, TAYLOR, MORTENSEN & SANDERS, and Plaintiff, MARGARET M. SPRIGGS ("Spriggs"), by and through her counsels of record, CHARLES R. KOZAK, ESQ. and R. CRAIG LUSIANI, ESQ., and files this Supplemental Joint Case Management Report. I. DISCOVERY PLAN a. Deadline for completion of discovery: June 5, 2016 b. Deadline for
Summary: SUPPLEMENTAL JOINT CASE MANAGEMENT REPORT VALERIE P. COOKE , Magistrate Judge . COMES NOW Defendant, CMH Homes, Inc. ("CMH"), by and through its attorneys of record, ALVERSON, TAYLOR, MORTENSEN & SANDERS, and Plaintiff, MARGARET M. SPRIGGS ("Spriggs"), by and through her counsels of record, CHARLES R. KOZAK, ESQ. and R. CRAIG LUSIANI, ESQ., and files this Supplemental Joint Case Management Report. I. DISCOVERY PLAN a. Deadline for completion of discovery: June 5, 2016 b. Deadline for ..
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SUPPLEMENTAL JOINT CASE MANAGEMENT REPORT
VALERIE P. COOKE, Magistrate Judge.
COMES NOW Defendant, CMH Homes, Inc. ("CMH"), by and through its attorneys of record, ALVERSON, TAYLOR, MORTENSEN & SANDERS, and Plaintiff, MARGARET M. SPRIGGS ("Spriggs"), by and through her counsels of record, CHARLES R. KOZAK, ESQ. and R. CRAIG LUSIANI, ESQ., and files this Supplemental Joint Case Management Report.
I. DISCOVERY PLAN
a. Deadline for completion of discovery: June 5, 2016
b. Deadline for amending pleadings and adding parties: March 7, 2016
c. Dates for completion of disclosure of expert testimony: April 6, 2016
d. Deadline for disclosure of rebuttal experts: May 6, 2016
e. Deadline for filing of dispositive motions: July 5, 2016
f. Date by which parties will file the Joint Pretrial Order: August 4, 2017
II. REQUIRED DISCOVERY
a. The Parties contemplate the need for deposition discovery as well as documentary discovery in this case which will include discovery of relevant Plaintiff's medical records and protected health care information.
b. The discovery contemplated is anticipated to originate in the states of Nevada, California and Tennessee. Defendant anticipates conducting deposition discovery of the Plaintiff prior to the settlement conference.
III. SETTLEMENT CONFERENCE
a. The parties request that an Early Settlement Conference be scheduled for this case prior to the July 5, 2016 deadline for filing dispositive motions.
IV. ISSUE(S) RELATING TO DISCLOSURE OR DISCOVERY OF ELECTRONICALLY STORED INFORMATION (ESI)
a. There are no currently existing issues relating to discovery or disclosure of electronically stored information (ESI). Discovery of ESI is contemplated, however, and Plaintiff reserves the right to raise issues as and/or when disagreement arises.
V. ISSUES RELATED TO CLAIMS OF PRIVILEGE OR WORK PRODUCT
a. There are no current issues related to claims of privilege or work product.
VI. JURY TRIAL
a. Plaintiff has requested a jury trial.
VII. TRIAL LENGTH
a. The parties anticipate a trial in this case will last approximately 3 to 5 days.
VIII. REVISIONS TO DISCOVERY LIMITATIONS
a. There are no suggested revisions to the discovery limitations imposed by the Federal Rules of Civil Procedure and Local Rules 26(1)(c).
b. It is anticipated that any individual deposition(s) should not exceed six hours unless extended by agreement of the parties.
IX. PENDING MOTIONS
a. There are no pending motions at this time.
X. ADDITIONAL PARTIES TO BE ADDED
a. Neither party currently anticipates adding additional party(ies), however, subject to developments as discovery continues the parties would reserve the right to request an opportunity to do so from this honorable Court.
XI. ADR
a. The parties are discussing alternative dispute resolution options, including, but not limited to, mediation and/or arbitration.
b. Defendant reserve the right to compel arbitration under the parties' arbitration agreement.
Pursuant to NRS 239B.030 the undersigned certify no Social Security numbers are contained in this document.
DATED this 12th day of February, 2016. DATED this 12th day of February, 2016.
ALVERSON, TAYLOR, KOZAK LUSIANI LAW
MORTENSEN & SANDERS
/s/ Trevor R. Waite /s/ R. Craig Lusiani
KURT R. BONDS, ESQ. CHARLES R. KOZAK, ESQ.
Nevada Bar #6228 Nevada Bar #11179
TREVOR R. WAITE, ESQ. R. CRAIG LUSIANI, ESQ
Nevada Bar # 13779 Nevada Bar #552
7401 W. Charleston Boulevard 3100 Mill Street, Suite 115
Las Vegas, NV 89117 Reno, Nevada 89502
Attorney for Defendants Attorneys for Plaintiff
IT IS SO ORDERED.
