Layton v. Green Valley Village Community Association, et al

Filing 50

ORDER Granting 49 Stipulation to Extend Time. Discovery due by 6/25/2015. Motions due by 7/24/2015. Proposed Joint Pretrial Order due by 8/25/2015. Signed by Magistrate Judge George Foley, Jr on 4/23/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01347-GMN-GWF Document 49 Filed 04/22/15 Page 1 of 3

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GEORGE B HIBBELER, ESQ.
Nevada Bar No: 7746
871 Coronado Center Dr., Ste. 200
Henderson, NV 89052
(702) 804-427e
Fax: [phone]
george@georgehibbeler. com
A tto rn ey .for P I a i nt i

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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THOMAS LAYTON:

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Plaintifl,

No. 2l4-cv-01347GMN-GWF

Case

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VS.

GREEN VALLEY VILLAGE COMMTINITY
ASSOCIATION, a Nevada not for profit
Corporation dba GREEN VALLEY VILLAGE
HOA; ASSURED REAL ESTATE, INC., a
Nevada Corporation; TERRA WEST
COLLECTIONS GROUP. LLC, a Nevada
Limited Liability Company dba ASSESSMENT
MANAGEMENT SERVICES; JOSEPH
YAKUBIK, an individual; DOES I-X inclusive;
ROE ; CORPORATIONS XI-XX inclusive:

STIPULATION AND
ORDER TO CONTINUE
T}IE SCHEDULED
Df,POSITIONS AND
EXTAND DAADLTNE FOR
COMPLETION OF
DISCOVERY AND OTHER
PENDING DEADLINES.

(First Request)

Defendant(s).

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The parties herein, through their respective counsel, hereby stipulate and agree that the
itions of Michael Unger and Jospeh Yakubic scheduled for April 22.2015 and the deposition

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April 23,2015 be continued. That the deadline for completion

of discovery which is currently, April 24,2015, be extended by sixty (60) days until June 25, 2015

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zo That the pending date for filing dispositive motions
also be extended sixty days until lulv 24. 2015.
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hat the (Joint) Pretrial Order is required on or before August 25,2015 or 30 days after the

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Case 2:14-cv-01347-GMN-GWF Document 49 Filed 04/22/15 Page 2 of 3

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ision deciding the dispositive motion. This is the parties first request fbr an extension of these

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deadlines. This stipulation is made in good faith and is not anticipated or intended to cause any

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delay to any party and good cause exists as follows:

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(1)

Interrogatories and requests for production of documents to Plaintifi Thomas

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Layton were served by Defendant on or about March 25,2015. Responses are due on April 25,

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2015. The depositions of Michael Unger and Jospeh Yakubic were scheduled

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(2)

for April23,20lS.

No other discovery remains to be completed but the interrogatories, requests for

production of documents and depositions stated previously.

(3)

The discovery remains to be completed because, despite the parties diligent

ttempts to schedule the depositions during the months of March and April, due to conflicts in

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the deposition of Thomas Layton was scheduled

for April22,2015

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their schedules, the parties were not able to agree to deposition dates. The deposition of Thomas

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Layton was scheduled on April

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Yakubic had been scheduled for April 22,2015. However, both Michael Unger and Joseph

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,201 5 and the depositions of Michael Unger and Joseph

l5 Yakubic are unavailable due to schedule conflicts on April 22,2015 and Defbndants contend that

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they were not given sufficient notice for this deposition date. Plaintiffcontends that the notice was

icient

(4)

Therefore, rather than burdening the court with unnecessary litigation of this issue,

the parties have agreed that the scheduled depositions be continued and tentatively rescheduled fbr

May l4'r' and l5'h and the deadline of completion of discovery be extended for sixty (60) days to

une25,2015. That the pending date for filing dispositive motions also be extended sixty

days

untilJuly24"2075. Thatthe(Joint)PretrialOrderisrequiredonorbeforeAugust25,20l5or30

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Case 2:14-cv-01347-GMN-GWF Document 49 Filed 04/22/15 Page 3 of 3

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days after the decision deciding the dispositive motion

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DATED

this

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day of

_April_

2015

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HIBBELER, ESQ.

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GEORGE

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By: /s/ George B. Hibbe

GREENBERG TRAURIG, LLP

By: /s/ Leslie S.Godfrry

George B Hibbeler, Esq.
Nevada Bar No. 7746
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871 Coronado Center Dr., Ste. 200
Henderson, Nevada 89012
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Tyler R. Andrews, Esq.
Nevada Bar No. 9499
Leslie S. Godfrey, Esq.
Nevada Bar No. 1A229
Greenberg Traurig, LLP
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, Nevada 89169

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At torney

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IT IS SO ORDERED

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Dated.

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April 23, 2015