Hedgepeth v. Meiborg Bros, Inc.

1 || ROBERT T. EGLET ROBERT T. EGLET Nevada Bar No. 3402 Nevada Bar No. 3402 TRACY A. EGLET TRACY A. EGLET || Nevada Bar No. 6419 Nevada Bar No. 6419 BRITTNEY R. GLOVER ROBERT M. ADAMS || Nevada Bar No. 15412 Nevada Bar No. 6551 EGLET ADAMS EGLET ARTEMUS W. HAM, IV HAM HENRIOD Nevada Bar No. 7001 || 400 South 7" Street, #400 JOEL D. HENRIOD Las Vegas, Nevada 89101 Nevada Bar No 8492 eservice @egletlaw.com CHAD M. GOLIGHTLY 8 Nevada Bar No. 5331 EGLET ADAMS & GOLIGHTLY, PLLC 9 400 South 7" Street, 4 Floor 10 Las Vegas, Nevada 89101 || CHAD M. GOLIGHTLY, ESQ. nO Nevada Bar No. 5331 |} LAW OFFICES OF CHAD M.

3 GOLIGHTLY, LTD ll 9560s. Eastern Ave., Ste. 240 Z 14 || Las Vegas, NV 89123 Attorneys for Plaintiff 16 UNITED STATES DISTRICT COURT 17 DISTRICT OF NEVADA || TIFFANY HEDGEPETH, an individual, CASE NO.: 2:24-cv-00045-CDS-MDC 19 Plaintiff, AMENDED STIPULATION AND 20 [PROPOSED] ORDER TO EXTEND Vs. DISCOVERY AND PRE-TRIAL 21 DEADLINES (THIRD REQUEST) MEIBORG - BROS, INC., an __ Illinois Corporation; MEIBORG, INC., an Illinois 23 Corporation; JAMES RAY COX, an individual; DOES I through X, inclusive; ROE BUSINESS || ENTITIES I through X, inclusive; Defendants.

27 In accordance with Local Rules of Practice for the United States District Court for the || District of Nevada LR 26-3, Plaintiff, TIFFANY HEDGEPETH, by and through her attorneys.

1 || Robert T. Eglet, Esq., Tracy A. Eglet, Esq., and Brittney R. Glover, Esq. of the law firm ot ||EGLET ADAMS EGLET HAM HENRIOD; and Defendants, MEIBORG BROS, INC. |} MEIBORG, INC. and JAMES RAY COX, by and through their attorneys, Mark R. Smith, Esq.

4 || and Robert L. Thompson, Esq. of the law firm of RESNICK & LOUIS, P.C., hereby stipulate || and agree to an extension of all discovery and pre-trial deadlines by ninety (90) days. The parties || propose the following revised discovery plan.

7 I. DISCOVERY COMPLETED 8 On January 5, 2024, Defendants removed this case to Federal Court.

9 1. On February 2, 2024, the parties attended the FRCP 26(f) discovery conference.

10 2. Plaintiff served her Initial Disclosures on February 15, 2024.

MQ 11 3. Defendant produced their Initial Disclosures on February 16, 2024.

3 = 12 4. Defendant Meiborg Bros, Inc. served its First Set of Interrogatories, Requests fo Q Z 13 || Production and Requests for Admission to Plaintiff on February 16, 2024. < 14 5. Plaintiff served her First Set of Interrogatories, Requests for Production □□□ IS Requests for Admission to Defendant James Ray Cox on February 20, 2024.

16 6. Plaintiff served her First Set of Interrogatories, Requests for Production □□□ "7 Requests for Admission to Defendant Meiborg Bros, Inc. on February 20, 2024.

Ped 8 7. Plaintiff served her First Set of Interrogatories, Requests for Production □□□ □ Requests for Admission on Defendant Meiborg, Inc. on February 20, 2024. > 8. Plaintiff served her first supplemental disclosures on March 22, 2024.

7 9. Plaintiff served responses to Defendant Meiborg Bros, Inc.’s First Set o Interrogatories and Requests for Admissions on April 5, 2024.

24 10. Plaintiff served her second supplemental disclosures on June 11, 2024.

25 11. Plaintiff served her third supplemental disclosures on July 2, 2024.

26 12. ‘Plaintiff served her responses to Defendant Meiborg Bros, Inc.’s First Set o || Requests for Production of Documents on Jul 10, 2024.

28 13. Plaintiff served her fourth supplemental disclosures on July 18, 2024.

1 14. Plaintiff served her second requests for production of documents to Defendant || Meiborg Bros, Inc. and Meiborg, Inc. on August 8, 2024.

3 15. Defendant served their first supplemental disclosures on August 29, 2024.

4 16. Defendant served their second supplemental disclosures on September 6, 2024.

5 17. Defendant James Ray Cox served his responses to Plaintiff's first set of request for production of documents on September 6, 2024.

7 18. Defendants Meiborg, Inc. and Meiborg Bros, Inc. served their responses □□ Plaintiff's first set of requests for production of documents on September 6, 2024. ° 19. Defendant James Ray Cox served his responses to Plaintiff's first set of request for admission and interrogatories on September 9, 2024.

3 D 20. Defendants Meiborg, Inc. and Meiborg Bros, Inc. served their responses □□ 0 13 Plaintiff's first set of requests for admissions and interrogatories on September 11, 2024. < 4 21. Defendant served their third supplemental disclosures on September 25, 2024.

15 22. Defendant served their fourth supplemental disclosures on October 9, 2024.

2 16 23. Plaintiff underwent the FRCP Rule 35 Examination on October 18, 2024.

17 24. Defendant Meiborg, Inc. served their responses to Plaintiff's second set of request O 5 18 || for production of documents on December 2, 2024. men 19 25. Defendant James Ray Cox was deposed on December 10, 2024.

20 I. DISCOVERY THAT REMAINS TO BE COMPLETED 21 The parties believe the following discovery remains to be completed: 22 1. Obtain authorizations from Plaintiff to request medical and billing records; 23 2. Additional written discovery requests to Defendants; 24 3. The deposition of Plaintiff; 25 A, The deposition of Defendants Meiborg Bros, Inc. FRCP 30(b)(6) Designee(s) ; 26 5. The deposition of Defendant Meiborg, Inc.’s FRCP 30(b)(6) Designee(s); “7 6. Depositions of Plaintiffs treating medical providers; *8 7. Any other party and witness depositions; 1 8. Subpoena duces tecum to third parties; 2 9. Designations of Initial and Rebuttal Expert Witnesses; 3 10. Depositions of Expert Witnesses; 4 11. Additional discovery as the parties deems necessary.

5 II. REASONS WHY DISCOVERY WAS NOT COMPLETED PRIOR TO 6 THE CUT-OFF 7 On June 20, 2024, this Honorable Court granted the parties’ Stipulation and Order t |] Extend Discovery and Pre-Trial Deadlines (ECF No. 27) to allow Eglet Adams Eglet Har || Henriod to review all materials to get up to speed on this case and for the parties to diligently an effectively continue their discovery efforts. As shown above, the parties have been diligent i AO WI their discovery efforts by requesting and serving written discovery, serving supplementa = 12 disclosures, conducting Plaintiff's FRCP 35 Examination, and deposing Defendant James Ra Z IS Cox. i" However, the parties still have additional discovery to conduct. Specifically, Plaintiff ha endured delays in her medical treatment that will impact the timeliness of designating expet : witnesses before the current initial expert disclosure deadline. Additionally, Plaintiff intends t serve subpoena duces tecum to third parties and additional written discovery because of testimon) elicited from Defendant James Ray Cox’s deposition. The parties still need to finalize the stipulat confidentiality order, which will result in the production of confidential documents that will nee |} be reviewed. The parties also need to conduct additional party and witness depositions. Bases || on these reasons, the parties respectfully submit the reasons set forth above constitute good caus: || for this extension.

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1 IV. CURRENT AND PROPOSED SCHEDULE FOR COMPLETING ALL 2 REMAINING DISCOVERY Amend Pleadings and Add Parties December 26, 2024 March 26, 2025 Initial Expert Disclosures January 27, 2025 April 28, 2025 Rebuttal Expert Disclosures February 24, 2025 May 28, 2025 Close of Discovery March 24, 2025 June 27, 2025 Joint Pretrial Order May 22, 2025 August 27, 2025 NO 11 O 2 The Parties aver that this request for extension of discovery and pre-trial deadlines is mad: QO 13 || by the parties in good faith and not for the purpose of delay. <u IT IS SO STIPULATED.

DATED this 20th day of December 2024. DATED this 20" day of December 2024. v7 EGLET ADAMS EGLET HAM RESNICK & LOUIS, P.C.

HENRIOD OO 18 fl] /s/Brittney R. Glover, Esq. /s/ Robert L. Thompson, Esq.

19 ROBERT T. EGLET, ESQ. MARK R. SMITH, ESQ.

20 Nevada Bar No. 3402 Nevada Bar No. 11872 TRACY A. EGLET, ESQ. ROBERT L. THOMPSON, ESQ.

21 Nevada Bar No. 6419 Nevada Bar No. 9920 BRITTNEY R. GLOVER, ESQ. Attorneys for Defendants, 22 Nevada Bar No. 15412 Meiborg Bros., Inc., Meiborg, Inc., 3 Attorney for Plaintiff, and James Ray Cox Tiffany Hedgepeth 1 Hedgepeth v. Meiborg Bros, Inc. et a Case No.: □□□□□□□□□□□□□□□□□□□□□ 2 Amended Stipulation and [Proposed]Order To Extend Discovery Deadlines and Pre-Trial Deadline ( 3" Reques ° ORDER 4 Based upon the foregoing stipulation of counsel and good cause appearing, IT I > HEREBY ORDERED, ADJUDGED, AND DECREED: Hh], The discovery cut- off shall be Friday, June 27, 2025.

7 \h2. Amending the Pleading and Adding Parties. The lase date for filing motions to amer || pleadings or to add parties shall not be later than 90 days prior to the close of discovery. In th || action, the last date to file motions to amend the pleadings or add parties shall be Wednesda || March 26, 2025. nO 11 || 3: FRCP _26(4)(2) Disclosure (Experts). The last day to disclose expert witnesses shall be ¢ || days before the discovery cut-off date. In this action, the last date to disclose experts shall | B Monday, April 28, 2025. The date for the disclosure of rebuttal expert witnesses shall be 30 da < 4 after the initial disclosure of experts. In this action, the last date to disclose rebuttal experts be Wednesday, May 28, 2025.

4. Dispositive Motions. The last date to file dispositive motions shall not be later than days after the discovery cut-off date. In this action, the last date to file dispositive motions sh< 14 17 lI he Monday, July 28, 2025 0 18 |Is, Joint Pretrial order. The joint Pretrial Order shall be filed no later than 30 days after tl || date set for filing dispositive motions. In this action, the joint pretrial order shall be filed on « || before Wednesday, August 27, 2025.

21 || 6. FRCP _26(a)(3)_ Disclosures. The disclosures required by FRCP 26(a)(3) and ar || objections thereto shall be included in the Joint Pretrial Order.

23 IT IS SO ORDERED.

24 ‘ a = 25 J haf Lo 56 UNITED Pp ORR JUDGE □ ff 27 D At. 12-30-24 fff fo 28 / j