Melamed v. Jaguar Land Rover North America, LLC

• Court: District Court, D. Nevada
• Decided: August 27, 2025
• Docket: 2:25-cv-00720
• Status: Unknown

Opinion

1 2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 SAMIRA MELAMED, 5 Case No. 2:25-cv-00720-JCM-NJK Plaintiff(s), 6 Order v. 7 [Docket Nos. 13, 15] JAGUAR LAND ROVER NORTH 8 AMERICA, LLC, 9 Defendant(s). 10 Pending before the Court is a stipulation to extend case management deadlines by 90 days. 11 Docket No. 15; see also Docket No. 13-14 (earlier version of stipulation and errata). 12 A request to extend unexpired deadlines in the scheduling order is governed by Rule 16 of 13 the Federal Rules of Civil Procedure.1 “The Ninth Circuit is protective of this particular rule, as it 14 deems Rule 16 to be an essential tool in controlling heavy trial court dockets.” Williams v. James 15 River Grp. Inc., 627 F. Supp. 3d 1172, 1177 n.3 (D. Nev. 2022) (quoting Gerawan Farming, Inc. 16 v. Rehrig Pac. Co., No. 1:11-cv-01273-LJO-BAM, 2013 WL 645741, at *4 (E.D. Cal. Feb. 21, 17 2013)). Indeed, the Ninth Circuit has “repeatedly and emphatically addressed the importance of 18 scheduling orders as tools for district courts to manage their heavy caseloads.” Desio v. State 19 Farm Mut. Auto. Ins. Co., 339 F.R.D. 632, 641 (D. Nev. 2021) (collecting cases). As articulated 20 in one of those cases: 21 A scheduling order “is not a frivolous piece of paper, idly entered, which can be cavalierly disregarded by counsel without peril.” The 22 district court’s decision to honor the terms of its binding scheduling order does not simply exalt procedural technicalities over the merits 23 of [the] case. Disregard of the order would undermine the court’s ability to control its docket, disrupt the agreed-upon course of the 24 litigation, and reward the indolent and the cavalier. 25 Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 610 (9th Cir. 1992) (internal citation 26 omitted). Given the importance of scheduling orders and the well-established expectation that 27

28 1 Such a request is also governed by Local Rule 26-3. 1 they be taken seriously, “enforcement of such an order should come as a surprise to no one.” 2 Cornwell v. Electra Cent. Credit Union, 439 F.3d 1018, 1027 (9th Cir. 2006).2 3 The Rule 16 good cause analysis for obtaining relief from the scheduling order turns on 4 whether the subject deadlines cannot reasonably be met despite the exercise of diligence. Johnson, 5 975 F.2d at 609. “The diligence obligation is ongoing.” Morgal v. Maricopa Cnty. Bd. of 6 Supervisors, 284 F.R.D. 452, 460 (D. Ariz. 2012). “The showing of diligence is measured by the 7 conduct displayed throughout the entire period of time already allowed.” Williams, 627 F. Supp. 8 3d at 1177 (citing Muniz v. United Parcel Serv., Inc., 731 F.Supp.2d 961, 967 (N.D. Cal. 2010) 9 and Jackson v. Laureate, Inc., 186 F.R.D. 605, 607 (E.D. Cal. 1999)). “[C]arelessness is not 10 compatible with a finding of diligence and offers no reason for a grant of relief.” Johnson, 975 11 F.2d at 609. When diligence has not been shown in support of an extension request, “the inquiry 12 should end.” Id.3 13 The reasons advanced for the extension requested in this case are largely baseless. The 14 fact that Plaintiff violated the Court’s order to serve initial disclosures two months ago is certainly 15 2 The Ninth Circuit has at times taken a softer approach to extensions of deadlines outside 16 the Rule 16 context, such as those related to briefing schedules. See Ahanchian v. Xenon Pics., Inc., 624 F.3d 1253, 1257-60 (9th Cir. 2010); but see Ratha v. Phatthana Seafood Co., 35 F.4th 17 1159, 1181 (9th Cir. 2022) (distinguishing Ahanchian and affirming denial of request to extend “stringent” briefing schedule). Given the robust body of law specific to the Rule 16 context, the 18 Court does not apply the standards discussed in these other cases. See, e.g., Williams, 627 F. Supp. 3d at 1177 n.3 (citing Espinosa v. Corrections Corp. of Am., No. 2:19-cv-01617-RFB-NJK, 2021 19 WL 4186694, at *1 n.1 (D. Nev. Aug. 23, 2021)). 20 3 A showing of diligence is required regardless of whether the request to modify case management deadlines is presented by stipulation: 21 When a request to extend case management deadlines is made by 22 stipulation, courts may consider the joint nature of the request in deciding whether the circumstances warrant an amendment to the 23 scheduling order. Nonetheless, courts addressing such requests are deciding at bottom whether to modify their own orders, an issue that 24 need not be based necessarily on the promptings of the parties. . . . That a request is made jointly neither mandates allowance of the 25 extension sought nor exempts parties from making the necessary showings to justify that relief. Failure to provide such showings 26 may result in denial of a stipulated request to extend the case management deadlines. 27 Williams, 627 F. Supp. 3d at 1178 (internal citations omitted); accord Lux v. Buchanan, No. 2:23- 28 cv-00839-MMD-NJK, Docket No. 49 (D. Nev. Nov. 1, 2023) (Du, C.J.) (affirming denial of stipulation to extend case management deadlines based on lack of diligence). 1] not good cause to modify case management deadlines.4 The fact that the parties discussed settlement fails as a matter of law to justify a post-hoc request to modify case management deadlines. Williams, 627 F. Supp. 3d at 1181 (collecting cases). On the other hand, the stipulation 4] represents that efforts have been made to obtain documents from non-parties, who have been “slow 5] to respond.” Docket No. 15 at 2. Although no details are provided as to those efforts, but see Local Rule 26-3(a) (requiring specification of discovery conducted),° they may nudge this request 7| over the line in that at least some extension to the case management deadlines is warranted (though, 8|| not 90 days). In an effort for the case to be decided on its merits and as a one-time courtesy to the 9] parties, the Court will allow a 45-day extension to the unexpired case management deadlines. 10 Accordingly, the stipulation to extend (Docket No. 15) is GRANTED in part and DENIED 11] in part, while the earlier iteration of the stipulation (Docket No. 13) is DENIED as moot. 12|| Deadlines are RESET as follows: 13 e Amend pleadings/ add parties: closed 14 e Initial experts: October 9, 2025 15 e Rebuttal experts: November 10, 2025 16 e Discovery cutoff: December 8, 2025 17 e Dispositive motions: January 7, 2026 18 e Joint proposed pretrial order: February 6, 2026 19 The Court is not inclined to extend these deadlines further, so counsel must take all reasonable steps to meet these deadlines as now set. 21 IT IS SO ORDERED. 22 Dated: August 27, 2025

Nancy J. Koppe 24 United States Magistrate Judge 25 26) ———______ ‘ That violation is being addressed in an order to show cause issued concurrently herewith. > Moreover, it is also not entirely clear that these are non-parties in the traditional sense, as 28]| Defendant appears to be seeking documents from its own affiliates.