UMRO Realty Corp. v. The Agency, Inc.

Filing 26

ORDER Granting 25 Stipulation for Extension of Time re Expert Discovery Deadlines (First Request). See Order for deadlines. Signed by Magistrate Judge Carl W. Hoffman on 5/19/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:16-cv-02130-JCM-CWH Document 25 Filed 05/18/17 Page 1 of 4

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KAEMPFER CROWELL
Robert McCoy, No. 9121
Joni A. Jamison, No. 11614
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff Umro Realty Corp
d/b/a The Agency

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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UMRO REALTY CORP d/b/a THE
AGENCY,

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Plaintiff,
STIPULATION AND ORDER TO
EXTEND EXPERT DISCOVERY
DEADLINES

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vs.
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Case No. 2:16-cv-02130-JCM-CWH

THE AGENCY, INC.,
(FIRST REQUEST)

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Defendant.

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The parties stipulate to extend the currently scheduled expert discovery deadlines

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by 60 days.

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stipulation, the parties state as follows:

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I.

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This is the first requested extension of these deadlines.

In support of this

DISCOVERY COMPLETED
A.

Fed. R. Civ. P. 26(a)(1) Initial Disclosures:
Both parties served their initial disclosures on March 14, 2017.

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KAEMPFER CROWELL
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

1975853_1.docx

Page 1 of 4

Case 2:16-cv-02130-JCM-CWH Document 25 Filed 05/18/17 Page 2 of 4

B.

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Written Discovery:

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Plaintiff served defendant with interrogatories, requests for production of

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documents, and requests for admission on December 9, 2016. Defendant responded to these

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written discovery requests on January 20, 2017 and has agreed to supplement these responses by

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May 22, 2017.

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Defendant served plaintiff with interrogatories, requests for production of

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documents, and requests for admission on April 21, 2017. Defendant has granted plaintiff an

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extension to respond or object to these written discovery requests by June 20, 2017.
C.

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Depositions:

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Plaintiff has noticed the deposition of the following witnesses for the following

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dates, though the parties are still negotiating the potential rescheduling of some of these

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depositions:

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Kathryn Holbert

June 12, 2017, 9:00 a.m.

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Marie Wdzieczkewski

June 16, 2017, 9:00 a.m.

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The Agency, Inc. (30(b)(6)) June 19, 2017, time to be determined

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Randolph Reyes

June 20, 2017, time to be determined

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Lenny Gervasio

June 21, 2017, time to be determined

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REMAINING DISCOVERY TO BE COMPLETED

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Defendant still owes plaintiff supplemental discovery responses, as noted above.

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Plaintiff also still has outstanding discovery responses that are due on June 20, 2017. In

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addition, plaintiff plans to take the depositions noted above in June 2017. The parties may

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depose additional witnesses and issue additional written discovery requests to one another.

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KAEMPFER CROWELL
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

1975853_1.docx

Page 2 of 4

Case 2:16-cv-02130-JCM-CWH Document 25 Filed 05/18/17 Page 3 of 4

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REASON FOR EXTENSION OF DISCOVERY DEADLINES

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The current deadlines for disclosure of expert witnesses are June 8, 2017 for

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initial expert disclosures and July 7, 2017 for rebuttal disclosures. Due to the outstanding

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discovery requests that the parties are currently working on, the parties wish for additional time

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to complete this written discovery before they have to disclose their expert witnesses. In

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addition, plaintiff wishes to complete the depositions noted above before its expert disclosures

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are due. The parties have thus agreed to a modest 14-day extension of the expert discovery

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deadlines only, to allow the parties sufficient time to finish their written discovery and depose

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these witnesses. This is the first request to extend these deadlines. The parties do not request to

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extend any other currently scheduled deadlines at this time.

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IV.

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PROPOSED CHANGES TO DISCOVERY DEADLINES
A.

The parties propose that the deadlines for Fed. R. Civ. P. 26(a)(2) disclosure of

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Fed. R. Civ. P. 26(a) Disclosures (Experts):

experts and expert reports be extended as follows:
1.

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The parties shall disclose experts and expert reports by Thursday, June 22,
2017, which is 46 days before the discovery cut-off date;

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2.

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The parties shall disclose rebuttal experts and their reports by Friday, July
21, 2017, which is 17 days before the discovery cut-off date.

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KAEMPFER CROWELL
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

1975853_1.docx

Page 3 of 4

Case 2:16-cv-02130-JCM-CWH Document 25 Filed 05/18/17 Page 4 of 4

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B.

The parties do not request that the Court extend any other deadlines at this time.

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Other Deadlines:

KAEMPFER CROWELL

FISHERBROYLES, LLP

By /s/ Joni A. Jamison
Robert McCoy, No. 9121
Joni A. Jamison, No. 11614
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

By /s/ Rob Phillips
Rob Phillips
FisherBroyles, LLP
5670 Wilshire Blvd, Suite 1800
Los Angeles, CA 90036
Attorney for Defendant

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BARNES & THORNBURG LLP
By /s/ Jonathan P. Froemel
Michael A. Carrillo (pro hac vice)
Jonathan P. Froemel (pro hac vice)
Genevieve E. Charlton (pro hac vice)
One North Wacker Drive
Suite 4400
Chicago, Illinois 6060

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Attorneys for Plaintiff
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ORDER

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IT IS SO ORDERED.

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________________________________________
UNITED STATES DISTRICT COURT JUDGE
MAGISTRATE

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May 19, 2017
DATED:________________________________

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KAEMPFER CROWELL
1980 Festival Plaza Drive
Suite 650
Las Vegas, Nevada 89135

1975853_1.docx

Page 4 of 4