The Hackett Miller Company, Inc. v. GFour Productions, LLC et al

Filing 33

ORDER Granting 32 Stipulation for Extension of Time. (Discovery Plan/Scheduling Order due by 5/5/2017.) Signed by Judge Richard F. Boulware, II on 5/2/17. (Copies have been distributed pursuant to the NEF - ADR)

1

6

Ryan Gile, Esq.
Nevada Bar No. 8807
[e-mail]
F. Christopher Austin, Esq.
Nevada Bar No. 6559
[e-mail]
WEIDE & MILLER, LTD.
7251 W. Lake Mead Blvd., Suite 530
Las Vegas, NV 89128-8373
Tel: [phone]
Fax: [phone]

7

Attorneys for Plaintiff The Hackett Miller Company, Inc.

2
3
4
5

8
UNITED STATES DISTRICT COURT
9
DISTRICT OF NEVADA
10
11

THE HACKETT MILLER COMPANY, INC., a
Nevada corporation,

12
13
14
15

Plaintiff,
v.
GFOUR PRODUCTIONS, LLC, a Florida limited
liability company; and SPOTLIGHT RIGHTS,
LLC, a Florida limited liability company,

Case No.: 2:16-cv-00418-RFB-NJK
STIPULATION AND (PROPOSED)
ORDER FOR EXTENSION OF TIME
FOR PARTIES TO FILE A
DISCOVERY PLAN AND
SCHEDULING ORDER PURSUANT
TO THE COURT’S ORDER DATED
MARCH 31, 2017
(Second Request)

16

Defendants.

17
18
19

Plaintiff THE HACKETT MILLER COMPANY, INC. (“Plaintiff”), and Defendants

20

GFOUR PRODUCTIONS, LLC and SPOTLIGHT RIGHTS LLC (“Defendants”), by and

21

through their undersigned counsel, hereby stipulate and agree to a second 14-day extension of

22

time up to and including May 5, 2017, for the parties to file a Joint Discovery Plan and Scheduling

23

Order with the Court pursuant to the Court’s Minute Order dated March 31, 2017 (ECF No. 29).

24

On March 30, 2017, the Court denied without prejudice Defendant’s Motion to Dismiss

25

for (1) Lack of Personal Jurisdiction, (2) Failure to Join a Necessary Party, and (3) Improper

26

Venue, and (4) Request to Transfer Venue (ECF No. 22) and ordered the parties to engage in

27

jurisdictional discovery for a period of 60 days commencing March 31, 2017, and to submit a

28

joint proposed discovery/scheduling order within one week from March 31, 2017.

W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4292

1

1

On April 7, 2017, the parties filed a stipulation to extend the time to file a discovery plan

2

for 14 days (ECF No. 30) because the parties had reached a settlement framework which would

3

dismiss the action entirely and wanted additional time to allow the parties to finalize settlement

4

in the form of a formal written settlement agreement. On April 10, 2017, the Court granted the

5

stipulation of the parties (ECF No. 31). While Plaintiff’s counsel diligently prepared a draft

6

written settlement agreement for Defendants’ review (and even offered to provide an unapproved

7

draft to Defendants’ counsel in order to allow Defendant to review the substance of the agreement

8

and keep the settlement process moving forward expeditiously), Plaintiff’s counsel was unable to

9

obtain client approval on the draft due to vacation travel plans by Plaintiff’s principals until April

10

17, 2017. Defendants’ counsel provided proposed revisions to the settlement agreement on April

11

20, 2017.

12

///

13

///

14

///

15

///

16

///

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///

W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4292

2

1

By this Stipulation, the parties request that the deadline to file a joint proposed discovery

2

plan/scheduling order be extended another 14 days to May 5, 2017. This is the second request for

3

an extension of time by both parties to file the joint proposed discovery/scheduling order. Good

4

cause exists for this second request because while the parties remain optimistic about the prospects

5

of settlement, they require additional time in order to address the remaining issues that exist

6

between the parties and finalize such settlement. For this reason, this stipulated second request is

7

made for good cause and not for purposes of delay.

8

Dated: April 21, 2017

Dated: April 21, 2017

9

Respectfully Submitted,

Respectfully Submitted,

/s/ Ryan Gile
Ryan Gile (NV Bar No. 8807)
[e-mail]
F. Christopher Austin (NV Bar No. 6559)
[e-mail]
WEIDE & MILLER. LTD.
7251 W. Lake Mead Blvd., Suite 530
Las Vegas, NV 89128
Tel: [phone]
Fax: [phone]

/s/Gene S. Winter
Gene S. Winter (pro hac vice)
gwinter @ssjr.com
Jonathan A. Winter (pro hac vice)
ST. ONGE STEWARD JOHNSTON AND
REENS LLC
986 Bedford Street
Stamford, CT 06905-5619
Tel: [phone]

10
11
12
13
14
15
16

Ronald D. Green (NV Bar No. 7360)
Alex J. Shepard (NV Bar No. 13582)
RANDAZZA LEGAL GROUP, PLLC
4035 S. El Capitan Way
Las Vegas, NV 89147
Tel: [phone]
[e-mail]

Attorneys for Plaintiff, The Hackett
Miller Company, Inc.

17
18
19

Attorneys for Defendants, GFour Productions,
LLC and Spotlight Rights, LLC

20
21

IT IS SO ORDERED.
22
23
UNITED STATES DISTRICT JUDGE
24
Dated:
25

May 2, 2017.

26
27
28
W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4292

3