United States District Court, D. North Dakota, Western Division
LAW FIRM, P.C., Mark V. Larson, ATTORNEYS FOR THE PLAINTIFFS.
SERKLAND LAW FIRM, Peter W. Zuger, Ian R. McLean, ATTORNEYS
FOR DEFENDANTS SECURE ENERGY SERVICES, INC., SECURE ENERGY
SERVICES, USA, LLC AND EUGENE DAVIS.
EBELTOFT . SICKLER . LAWYERS PLLC, Nicholas C. Grant, Lawyer,
Courtney A. Presthus, ATTORNEYS FOR DEFENDANT KEITH DANIEL
STIPULATION TO AMEND SCHEDULING/DISCOVERY
R. Hochhalter, Magistrate Judge.
to Rule 26(f) and the Court's Order dated October 9, 2019
(Doc. ID #34), counsel for the parties certify that they have
conferred to discuss the need to extend certain deadlines set
forth in the Scheduling/Discovery Plan (Doc. ID #13).
Plaintiffs Carita Burns and John Burns and Defendants Secure
Energy Services, Inc., Secure Energy Services, USA, LLC,
Eugene Davis, and Keith Daniel Klein (collectively
“Parties”), by and through their respective
counsel, hereby stipulate and agree to request that the
Scheduling/Discovery Plan be amended as follows:
parties shall make by January 14, 2019, Rule 26(a)(1)
disclosures including preliminary identification of
witnesses, evidence, damage calculations, and the production
of the insurance contract(s).
issues on which the parties need to conduct discovery are
liability and damages. Discovery will occur through
interrogatories and depositions of fact witnesses and need
not be conducted in phases.
parties shall have until May 1, 2020 to
complete fact discovery and to file discovery motions.
parties shall provide the names of expert witnesses and
complete reports under Rule 26(a)(2) as follows:
Plaintiffs' expert disclosures shall be due May
1, 2020. Treating physicians need not prepare
reports, only qualifications, unless they will express
opinions not reflected in the medical records.
Defendants' expert disclosures shall be due June
1, 2020. Reports will be served on other parties,
but not filed with the court.
parties shall have until August 1, 2020 to
complete discovery depositions of expert witnesses.
parties shall have until July 12, 2019, to move to join
parties shall have until July 12, 2019, to move to amend
pleadings to add claims or defenses, including claims for
parties shall have until July 12, 2019, to file other
nondispositive motions (e.g., consolidation, bifurcation).
parties shall have until March 13, 2019, to file threshold
motions (e.g., jurisdiction, qualified ...