Barnard v. Rednex Oilfield Rentals, LLC

CourtDistrict Court, D. New Mexico
DecidedJanuary 2, 2025
Docket2:23-cv-00290
StatusUnknown

This text of Barnard v. Rednex Oilfield Rentals, LLC (Barnard v. Rednex Oilfield Rentals, LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barnard v. Rednex Oilfield Rentals, LLC, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

ASHLEY BARNARD, individually, and next friend of C.B., a minor,

Plaintiffs,

v. No. 23-cv-00290 DHU/JHR

REDNEX OILFIELD RENTALS, LLC, and MICHAEL SUTER,

Defendants.

ORDER GRANTING PLAINTIFFS’ MOTION TO EXTEND PRETRIAL DEADLINE [DOC. 62].

THIS MATTER is before the Court on Plaintiffs’ Motion to Extend the Pretrial Motion Deadline filed on October 30, 2024. [Doc. 62]. Defendant Rednex Oilfield Rentals, LLC responded on November 8, 2024, and Plaintiffs replied on November 12, 2024. [Docs. 65, 66]. For the below reasons, the Court GRANTS Plaintiffs’ motion and extends the pretrial motions deadline to allow Plaintiffs to file a motion to exclude defense expert’s untimely opinion. I. BACKGROUND The Court entered a scheduling order in this case on June 6, 2023. [Doc. 12] and extended the deadlines therein on September 18, 2024 [Doc. 53]. Expert disclosures were due on February 27, 2024. [Doc. 12]. Under the scheduling order extension, October 29, 2024, became the pretrial motion and discovery deadline. [Doc. 62, at 1, 2]; [Doc. 53]. Because of scheduling difficulties, the deposition of defense expert Dr. Kristi Bagnell was not set until October 29, 2024. [Doc. 62, at 2]. Plaintiffs inform that “[t]he day before Dr. Bagnell’s deposition and pretrial motion deadline, while Plaintiffs’ counsel was traveling to Houston for the deposition, Defendants produced a Supplemental Expert Report authored by Dr. Bagnell.” Id. Plaintiffs filed this motion on October 30, the day after Dr. Bagnell’s deposition and two days after receiving the supplemental report. [Doc. 62]. II. BRIEFING

Plaintiffs urge the Court to extend the pretrial motion deadline to allow them to file a motion to exclude the supplemental report. They argue good cause for the extension because they became “aware of Dr. Bagnell’s Supplemental Expert Report just a day before the pretrial motion deadline and her deposition, which caused a short delay in drafting and filing the Motion to Exclude.” Id. at 2. This request only extends to Plaintiffs’ prospective motion to exclude, not to reopening the entire pretrial motion period. Id. at 3. Defendants posture that Plaintiffs’ disclosure of additional records after Dr. Bagnell’s initial report justified the supplemental report. [Doc. 65, at 1]. They rely on the Rule 26(e) duty to supplement, arguing it extends “both to information included in the report and to information given during expert depositions.” Id. at 2. Thus, Defendants say supplementation was timely disclosed

on October 28, which was “three months and six days prior to trial.” Id. Defendants also emphasize the lack of prejudice because the supplemental report “was substantively identical to her initial report as her opinions did not change.” Id. at 3. Thus, they criticize Plaintiffs’ reliance on the “temporal aspect of [the supplemental report] as the sole reason to exclude” without addressing the substantive similarity with the original expert report. Id. Plaintiffs reply that Defendants fail to address the key issue in the instant motion: whether good cause exists to extend the scheduling order. [Doc. 66, at 2]. In that regard, Plaintiffs note that Defendants’ “unavailing” prejudice and supplementation arguments go to the merits of exclusion, not deadline extension. Id. at 2, 3. Plaintiffs conclude good cause exists because the supplemental report improperly “strengthen[s] and improve[s]” the original expert report “which, in turn, prejudices Plaintiffs” and requires a deadline extension to move to exclude the additional expert report. Id. at 3. III. LEGAL STANDARDS

Federal Rules of Civil Procedure 6 and 16 respectively provide parameters for extensions of time generally and scheduling orders specifically. Rule 6(b)(1) allows a court to extend time for good cause when an act “may or must be done within a specified time” and that time has not expired. Fed. R. Civ. P. 6(b)(1). Good cause is “not a particularly demanding requirement.” Stark- Romero v. Nat'l R.R. Passenger Co. (AMTRAK), 275 F.R.D. 544, 547 (D.N.M. 2011). If the operative time has expired, however, a court may still extend time “if the party failed to act because of excusable neglect.” Fed. R. Civ. P. 6(b)(1)(B); OptumCare Mgmt., LLC v. Gutierrez-Barela, No. CV 20-474 RB/SCY, 2023 WL 1787888, at *1 (D.N.M. Jan. 25, 2023). Finding excusable neglect requires a showing of both good faith and reasonable basis for not complying in the original time period. OptumCare Mgmt., 2023 WL 1787888, at *1 (citing Stark-Romero, 275 F.R.D. at

547). Courts consider several circumstances when deciding if a party’s neglect is excusable: “(1) the danger of unfair prejudice to the opposing party; (2) the length of the delay caused by the neglect and its impact on the judicial proceedings; (3) the reason for the delay, and whether it was in the reasonable control of the moving party, and (4) the existence of good faith on the part of the moving party.” United States v. Torres, 372 F.3d 1159, 1162 (10th Cir. 2004). The reason for the delay is the core consideration. Hamilton v. Water Whole Intern. Corp., 302 F. App'x 789, 798 (10th Cir. 2008). Excusable neglect does not cure inadvertence, ignorance, or mistakes regarding the rules. Quigley v. Rosenthal, 427 F.3d 1232, 1238 (10th Cir. 2005). Rule 16(b) governs extension of scheduling order deadlines. Scheduling order modification requires good cause and the judge’s consent. Fed. R. Civ. P. 16(b)(4); Stark-Romero, 275 F.R.D. at 548. “Properly construed, ‘good cause’ means that scheduling deadlines cannot be met despite a party’s diligent efforts.” Id. (internal citation omitted). Thus, Rule 16(b) focuses on the movant’s

diligence rather than its motives or any prejudice to the opposing party. Cole v. Ruidoso Mun. Schs., 43 F.3d 1373, 1386 (10th Cir. 1994). Both Rule 6 and Rule 16 extensions fall within the trial court’s broad discretion. OptumCare Mgmt., 2023 WL 1787888, at *1; Stark-Romero, 275 F.R.D. at 548. IV. ANALYSIS At this juncture, Plaintiffs’ only ripe request is an extension of the pretrial motion deadline in order to file a motion to exclude Dr. Bagnell’s supplemental opinion. See [Doc. 62, at 2, 3]; [Doc. 62-1] (Plaintiffs’ proposed Motion to Exclude). Whether to exclude Dr. Bagnell’s supplemental report is not at issue. The Court agrees with Plaintiffs that good cause exists to grant

an extension of the scheduling order’s pretrial motion deadline. A. The Rule 6 analysis endorses extending the pretrial motions deadline. Because the original pretrial motions period has passed, the Court finds excusable neglect to extend time under Rule 6(b)(1)(B) governing general requests for time extensions. Plaintiffs have shown good faith and a reasonable basis for not filing their motion to exclude Dr. Bagnell’s supplemental report prior to the original October 29 pretrial motions and discovery deadline. See [Doc. 62, p. 2]. Dr. Bagnell’s deposition was also set for October 29, and Plaintiffs received her supplemental report at issue the day before. Id. This left Plaintiffs one day to review the supplemental report, compare it to the original, prepare accordingly for the deposition, travel to Houston, depose Dr. Bagnell, and file their motion to exclude the supplemental report.

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Related

United States v. Torres
372 F.3d 1159 (Tenth Circuit, 2004)
Quigley v. Rosenthal
427 F.3d 1232 (Tenth Circuit, 2005)
Hamilton v. Water Whole International Corp.
302 F. App'x 789 (Tenth Circuit, 2008)
Stark-Romero v. National Railroad Passenger Co.
275 F.R.D. 544 (D. New Mexico, 2011)

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Barnard v. Rednex Oilfield Rentals, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnard-v-rednex-oilfield-rentals-llc-nmd-2025.