Afsharalmanchi v. Otis Elevator Company

1 |} SAM RYAN HEIDARI, ESQ. SBN 13347 HEIDARI LAW GROUP, P.C.

2 |/611 South 6th Street Las Vegas, NV 89101 || Telephone: (702) 722-1500 Facsimile: (702) 722-1600 || E-mail: [email protected] E-Mail: [email protected] || Attorneys for Plaintiff 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA g EJY MANSOUR AFSHARALMANCHI, an Case No.: □□□□□□□□□□□□□□□□□□□□□□ individual; STIPULATION AND ORDER TO EXTENT 10 Plaintifé DISCOVERY PLAN AND SCHEDULING oe ORDER 11 y z 2 □ (Second Request) OTIS ELEVATOR COMPANY; a Foreign 13. || Corporation; DOES I through X; and ROE CORPORATIONS I through X, inclusive; 4 Defendants.

1s cE 16 = COMES NOW, Plaintiff MANSOUR AFSHARALMANCHI, by and through his attorney of record, the law firm HEIDARI LAW GROUP and Defendant OTIS ELEVATOR 18 COMPANY by and through its counsel of record, the law firms ROGERS, MASTRANGELO, 19 CARVALHO, AND MITCHELL and TUCKER ELLIS LLP, and hereby request the discovery |! deadlines in the previously filed Order [Doc 19] be extended by thirty (30) days, pursuant to || FRCP 29 and LR 26.4, as follows:.

22 A. DISCOVERY COMPLETED TO DATE 23 e The parties have conducted a FRCP 26(f) conference; 24 e The parties have served their respective FRCP 26(a) disclosures; 25 e Defendant has served upon Plaintiff one set of Requests for Production and one set 26 of Interrogatories. Plaintiff has responded.; 27 e Plaintiff provided provider specific authorizations; 1 e Defendant served a Subpoena Duces Tecum on Venetian Las Vegas Gaming, LLC 2 and obtained documents, photographs, and video surveillance.

3 e A site inspection of the Subject Elevator has been completed.

4 e Defendant has deposed Plaintiff.

5 e Defendant has completed an independent medical examination of Plaintiff 6 B. DISCOVERY TO BE COMPLETED AND REASONS FOR EXTENSION OF 7 DISCOVERY g Discovery to be completed includes: 9 e Plaintiff needs to depose other occupants in the elevator at the time of the Incident; e Plaintiff need to conduct expert discovery on Defendant ° e Depositions of numerous expert witnesses and rebuttal expert witnesses; e Additional written discovery and depositions are necessary g I e Parties are actively engaging in settlement negotiations ae 8 The parties agree, pursuant to Local Rule 6-1, that good cause exists for the requested 23 4 extension. Plaintiff Mansour Afsharalmanchi alleges serious injuries and other related damages IS as a result of an alleged elevator drop on August 3, 2022 at The Venetian Hotel. The parties have 16 been working diligently to complete discovery in this matter, however, they agree that it would be best to extend the current discovery plan an additional thirty (30) days in order to allow the 18 parties time to complete additional discovery, as well as engage in further settlement 19 negotiations. The parties wish to further investigate this case and potentially reach a resolution 20 prior to incurring fees and costs of physician and expert depositions. A brief extension in the || current discovery plan would assist in ensuring a comprehensive and equitable discovery process.

22 C. PROPOSED PLAN FOR COMPLETING DISCOVERY Event |Current Deadtine | __ Proposed Deadline September 25, 2028 October 27,2028 November 26, 2025 December 29,2028 January 28,3028 Current Deadline Proposed Deadline 2] [Dispositve Motions 3 D. THE CURRENT TRIAL DATE This matter has not been scheduled for trial.

E. NUMBER OF REQUESTS FOR EXTENSIONS 7 This 1s the second request to extend discovery deadlines.

9 Dated this 21st Day of August, 2025 Dated this 21st Day of August, 2025 10 HEIDARI LAW GROUP, P.C. Rogers, Mastrangelo, Carvalho & Mitchell = 11 = /s/ Sam Ryan Heidari /s/ Rebecca L. Masterangelo Se 12 SAM RYAN HEIDARI, ESQ. REBECCA L. MASTRANGELO, ESQ.

Nevada Bar No. 13347 Nevada Bar No. 5417 13 611 South 6" Street, 700 South Third Street, Las Vegas, NV 89101 Las Vegas, Nevada 89101 14 Attorneys for Plaintiff Attorneys for Defendant Otis Elevator Company 16 Dated this 21st Day of August, 2025 17 TUCKER ELLIS LLP 18 /s/ Su-Lyn Combs 19 SU-LYN COMBS, ESQ.

Nevada Bar No. 17058 20 515 South Flower Street Forty-Second Floor 21 Los Angeles, CA 90071 Attorneys for Defendant Otis Elevator 22 Company IT IS SO ORDERED.

25 Ko JY) el OS ral United Bjates Magystrate Judge 7 DATED: _ August 21, 2025