Lewis v. Delta Air Lines, Inc.

Filing 51

ORDER Granting 50 Stipulation Allowing Certain Depositions to Occur After the Close of Discovery Deadline. Signed by Magistrate Judge George Foley, Jr on 10/9/15. (Copies have been distributed pursuant to the NEF - TR)

Case 2:14-cv-01683-RFB-GWF Document 50 Filed 10/08/15 Page 1 of 2

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FISHER & PHILLIPS LLP
SCOTT M. MAHONEY, ESQ.
Nevada Bar No. 1099
300 South Fourth Street
Suite 1500
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
E-Mail Address: [e-mail]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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300 S Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

JOSEPH LEWIS,
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Plaintiff,
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vs.
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DELTA AIR LINES, INC.
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Defendant.
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___________________________________ )

Case No. 2:14-cv-01683-RFB-GWF
STIPULATION AND ORDER
ALLOWING CERTAIN
DEPOSITIONS TO OCCUR
AFTER THE DISCOVERY
DEADLINE AND EXTENDING
OTHER DEADLINES
(Second Request)

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IT IS HEREBY STIPULATED AND AGREED by and between the parties’

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counsel of record that one, and possibly two, depositions may occur after the present

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discovery deadline of October 16, 2015. Specifically, the parties have agreed that

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because of scheduling conflicts, the deposition of JoAnne Guerrant, who is located in

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Atlanta, will occur on November 5, 2015. Additionally, Plaintiff wishes to depose

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Delta’s in-house counsel, Kelly Giustina. While Defendant objects to the taking of this
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deposition, the parties have agreed to defer any deposition and any motion practice

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associated with the taking of this deposition until after the ruling on the privileged

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document issues raised in Plaintiff’s Motion for an In Camera Review of Select Items

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from Defendant’s Privilege Log (docket #41). Following the ruling, Defendant reserves

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FPDOCS 31092467.1

Case 2:14-cv-01683-RFB-GWF Document 50 Filed 10/08/15 Page 2 of 2

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the right to seek a protective order regarding the deposition of Ms. Giustina, but agrees

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that it will not object to the deposition on the basis that it is occurring after the

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discovery deadline. This is the second request for any extension of discovery in this

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case.
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IT IS FURTHER STIPULATED AND AGREED that because the taking or

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possible taking of the foregoing depositions will not occur until November or thereafter,

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the dispositive motion deadline will be extended to December 18, 2015 and the deadline

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for filing a Joint Pretrial Order will be extended to January 18, 2016, or if a dispositive

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motion is filed, within 30 days after the Court’s decision on any dispositive motions.

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300 S Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

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This would be the second extension of these deadlines.

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This Stipulation and Order has been filed within 21 days of the current
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discovery deadline because the parties have just been able to finalize their agreements

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and arrangements regarding these matters and good cause exists for the filing within 21

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days.

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STONE & WOODROW, LLP

FISHER & PHILLIPS LLP

/s/ Thatcher A. Stone, Esq.
Thatcher A. Stone, Esq.
250 West Main Street
Suite 201
Charlottesville, VA 22902
Attorney for Plaintiff

/s/ Scott M. Mahoney, Esq.
Scott M. Mahoney, Esq.
300 South Fourth Street
Suite 1500
Las Vegas, NV 89101
Attorneys for Defendant

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IT IS SO ORDERED:
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____________________________________
UNITED STATES MAGISTRATE JUDGE

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October 9, 2015
Dated:______________________________

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FPDOCS 31092467.1