Cosper v. Titanium Metals Corporation

Filing 28

ORDER Granting 27 Stipulation re Discovery Deadlines. Motions due by 1/12/2018. Signed by Magistrate Judge Carl W. Hoffman on 12/28/2017. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:16-cv-01548-JCM-CWH Document 27 Filed 12/27/17 Page 1 of 2

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Attorneys for Defendant
Titanium Metals Corporation
UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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ANTHONY L. MARTIN
Nevada Bar No. 08177
[e-mail]
ERICA J. CHEE
Nevada Bar No. 12238
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Wells Fargo Tower
Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]
Fax: [phone]

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DAVID COSPER, an individual,
Plaintiff,

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vs.

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TITANIUM METALS CORPORATION, a
Domestic Corporation; DOES 1 through X,
inclusive, ROE CORPORATIONS I through X,
inclusive,

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Case No.: 2:16-cv-01548-JCM-CWH
STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE AND
RESPOND TO DISPOSITIVE
MOTIONS
(SIXTH REQUEST)

Defendants.

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Defendant Titanium Metals Corporation (“Defendant”) and Plaintiff David Cosper

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(“Plaintiff”), by and through undersigned counsel, hereby stipulate and request that the dispositive

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motion deadline set forth in the current Stipulated and Order to Extend Discovery Deadlines (ECF

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No. 26) be extended by 2 weeks. The current deadline for dispositive motions is December 29,

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2017. The parties respectfully request that the deadline for dispositive motions be moved to

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January 12, 2018, and any response date by extended by two weeks. All other deadlines set forth

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in ECF No. 26 will remain the same. This request is submitted pursuant to LR 6-1, 6-2, 7-1 and

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26-4 and is the parties’ first request for an extension concerning only the dispositive motions, and

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the sixth request to extend deadlines pertaining to the parties scheduling order and discovery plan.

Case 2:16-cv-01548-JCM-CWH Document 27 Filed 12/27/17 Page 2 of 2

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There is good cause for this requested extension as the parties just received a copy of

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Plaintiff’s continued deposition transcript on December 19, 2017.

In addition, Defendant

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requested the extension, and Plaintiff and his counsel agreed, due to the holiday schedules and last-

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minute changes in travel for counsel and representatives from Defendant that necessitate additional

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time to review and evaluate dispositive motions.
The parties stipulate and request that dispositive motions must now be filed on or before

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Friday, January 12, 2018, and any response is to be filed on or before 35 days after service of the

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summary judgment, and no later than Friday, February 16, 2018. For all the reasons stated above,

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good cause exists to extend the dispositive motion deadline in this matter.

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Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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DATED this 27th day of December, 2017.

DATED this 27th day of December, 2017.

HATFIELD & ASSOCIATES, LTD.

OGLETREE, DEAKINS, NASH, SMOAK & STEWART,
P.C.

/s/ Trevor J. Hatfield
Trevor J. Hatfield
Nevada Bar No. 7373
703 South Eighth Street
Las Vegas, Nevada 89101
Attorneys for Plaintiff

/s/ Erica J. Chee
Anthony L. Martin
Nevada Bar No. 8177
Erica J. Chee
Nevada Bar No. 12238
Wells Fargo Tower
Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Attorneys for Defendant

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ORDER

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IT IS SO ORDERED.
U.S. MAGISTRATE JUDGE
December 28, 2017
DATE

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