Buesing Corporation, an Arizona corporation v. Helix Electric of Nevada LLC

Filing 36

ORDER Granting 34 Stipulation to Extend Discovery Deadline (Fourth Request). Discovery due by 2/13/2018. Signed by Magistrate Judge Nancy J. Koppe on 12/14/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-01439-JCM-NJK Document 34 Filed 12/13/17 Page 1 of 2

1
2
3
4
5
6
7

DICKINSON WRIGHT PLLC
Eric D. Hone (Nevada Bar No. 8499)
Email: [e-mail]
J. Gregory Cahill (Arizona Bar No. 012654)
Admitted Pro Hac Vice
Email: [e-mail]
8363 West Sunset Road, Suite 200
Las Vegas, Nevada 89113
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff/Counter-Defendant
Buesing Corporation
UNITED STATES DISTRICT COURT

8
9
10
11
12
13
14
15
16

DISTRICT OF NEVADA
BUESING CORPORATION, an Arizona
corporation,
Plaintiff,

Case No. 2:16-cv-01439-JCM-NJK
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
COMPLETE DISCOVERY

vs.
HELIX ELECTRIC OF NEVADA, LLC,
a Nevada Limited Liability Company, dba
HELIX ELECTRIC,
Defendants.

[FOURTH REQUEST]

AND RELATED CLAIMS.
Plaintiff/Counter-Defendant

17

Buesing

Corporation

(“Buesing”)

and

Defendant/

18

Counterclaimant Helix Electric of Nevada, LLC (“Helix”), by and through their respective

19

counsel, hereby stipulate and agree and further request that the Court extend the deadline to

20

complete discovery for a period of sixty (60) days—from December 15, 2017 to February 13,

21

2018.

22

The parties have been diligently prosecuting their claims, have continued to conduct

23

discovery, and recently attended a second mediation, but were unable to resolve the matter at that

24

time. Based on counsel and witnesses’ schedules, the parties need an additional sixty days to

25

complete remaining depositions. The parties do not request that the Court extend any other dates,

26

including the current deadlines to file dispositive motions (January 19, 2018) or to file a Joint

27

Pretrial Order on February 16, 2018. Other than completion of discovery and the briefing of

28
1

Case 2:16-cv-01439-JCM-NJK Document 34 Filed 12/13/17 Page 2 of 2

1

dispositive motions, the parties anticipate that the matter will be ready for trial after the filing of

2

the Joint Pretrial Order.

3

This is the fourth request to extend the deadline to complete discovery and is being made

4

within 21 days of the current deadline (December 15, 2017). The parties have had some

5

difficulty in securing dates for a number of the depositions, including the depositions of a

6

number of third party witnesses and former employees. This difficulty was exacerbated by

7

Thanksgiving and the impending holidays. The parties anticipated that they would have a

8

complete deposition schedule by the time they filed this request but were unable to do so in time

9

to file this request 21 days prior to discovery cutoff. Accordingly, they make this request in good

10
11
12
13

faith prior to the deadline passing.
The deadline to be extended, the current deadlines in parenthesis [ECF No. 32], and the
proposed new dates, are as follows:
• Discovery cut-off (December 15, 2017) to be February 13, 2018.

14

Dated this 13th day of December 2017.

Dated this 13th day of December 2017.

15

DICKINSON WRIGHT PLLC

PARKER, NELSON & ASSOCIATES,
CHTD.

/s/ Eric D. Hone
Eric D. Hone (NV Bar No. 8499)
J. Gregory Cahill (AZ Bar No. 012654)
Admitted Pro Hac Vice
8363 West Sunset Road, Suite 200
Las Vegas, Nevada 89113

/s/ Shana D. Weir
Theodore Parker, III (NV Bar No. 4716)
Shana D. Weir (NV Bar No. 9468)
2460 Professional Court, Suite 200
Las Vegas, Nevada 89128

Attorneys for Plaintiff/Counter-Defendant
Buesing Corporation

Attorneys for Defendant/Counterclaimant
Helix Electric of Nevada, LLC

16
17
18
19
20
21
22
23

ORDER

24

IT IS SO ORDERED:

25

____________________________________
U.S. MAGISTRATE JUDGE
United States Magistrate Judge

26

December 14, 2017
DATED: ___________________________

27
28
2