Hunt v. Zuffa, LLC et al

Filing 57

ORDER Granting 54 Stipulation for Extension of Time re 47 Motion to Stay (First Request). Responses due by 5/22/2017. Signed by Magistrate Judge Carl W. Hoffman on 5/4/17. (Copies have been distributed pursuant to the NEF - MR)

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CHRISTINA M. DENNING, ESQ. (CA Bar No. 211137)
[e-mail]
SCOTT J. INGOLD, ESQ. (NV Bar No. 11818)
[e-mail]
Higgs Fletcher & Mack LLP
401 West “A” Street, Suite 2600
San Diego, CA 92101-7913
T: 619.236.1551
F: 619.696.1410

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JAMES F. HOLTZ, ESQ. (NV Bar No. 8119)
[e-mail]
LAW OFFICE OF JAMES F. HOLTZ
1120 Town Center Drive, Suite 200
Las Vegas, NV 89144
T: 702.304.1803
F: 702.304.1822

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Attorneys for Plaintiff
MARK HUNT

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARK HUNT, an individual,

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Plaintiff,

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v.

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ZUFFA, LLC d/b/a ULTIMATE
FIGHTING CHAMPIONSHIP, a
Nevada limited liability company;
BROCK LESNAR, an individual;
DANA WHITE, an individual; and
DOES 1-50, inclusive,

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Case No.: 2:17-cv-00085-JAD-CWH
STIPULATION AND [PROPOSED]
ORDER RE: EXTENSION OF TIME
TO FILE OPPOSITION TO MOTION
TO STAY
[FIRST REQUEST]

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Defendants.

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H IGGS F LE TCHER &
M ACK LLP
ATTO RNEY S AT LAW
SAN DIEGO

112567-00001
7953291.1

STIPULATION AND [PROPOSED] ORDER RE:
EXTENSION TO FILE OPPOSITION TO MOTION TO STAY DISCOVERY
[FIRST REQUEST]
Case No.: 2:17-cv-00085-JAD-CWH

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Pursuant to Local Rules IA 6-1, 6-2, and LR 7-1, Plaintiff MARK HUNT (“Hunt”),

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and Defendants ZUFFA, LLC d/b/a ULTIMATE FIGHTING CHAMPIONSHIP

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(“Zuffa”), DANA WHITE (“White”) and BROCK LESNAR (“Lesnar”) hereby stipulate

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to extend the deadline for Hunt to file his Opposition to Zuffa and White’s Motion to Stay

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Discovery [Doc. 47] until May 22, 2017. This is the first such stipulation seeking this

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relief. This stipulation is based on the following:

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Defendants’ respective Motions to Dismiss pursuant to Fed. R. Civ. P. 12(b)(6)

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[Docs. 11 and 30] and are set to be heard on May 15, 2017 [See, Docs. 13 and 46]. Zuffa

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and White filed a Motion to Stay Discovery on April 20, 2017 [Doc. 47]. Lesnar joined in

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the Motion to Stay Discovery on April 26, 2017 [Doc. 52].

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Counsel for Hunt and counsel for Zuffa and White met and conferred regarding a

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potential stipulation that may dispose of or limit the scope of the Motion to Stay

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Discovery. Their meeting and conferring occurred via written correspondence on April

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25 and April 27, 2017, and via telephone discussion on May 1, 2017. Counsel for Hunt

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and counsel for Zuffa and White agreed that they would be in a better position to discuss a

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potential stipulation that may dispose of or limit the scope of the Motion to Stay

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Discovery following the May 15, 2017 hearing on the Motions to Dismiss. However,

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pursuant to LR 7-2(b), Hunt’s opposition to the Motion to Stay Discovery is due by May

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4, 2017. Therefore, the parties are requesting an extension of time for Hunt to file his

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opposition to Zuffa and White’s Motion to Dismiss (joined by Lesnar) until May 22,

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2017, one week following the hearing on Defendants’ Motions to Dismiss.

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Good cause exists for this Court to extend the date for Hunt to file his opposition to

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the Motion to Stay Discovery. No hearing date has been given for the Motion to Stay

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Discovery. Moreover, the parties agree that they are more likely to have productive

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discussions regarding a potential stipulation that may eliminate the need for or reduce the

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scope of the Motion to Stay following the May 15, 2017 hearing on Defendants’ Motion

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to Dismiss.

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H IGGS F LE TCHER &
M ACK LLP
ATTO RNEY S AT LAW
SAN DIEGO

Based on the foregoing, the parties hereby stipulate and request that the Court issue
112567-00001
7953291.1

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STIPULATION AND [PROPOSED] ORDER RE:
EXTENSION TO FILE OPPOSITION TO MOTION TO STAY DISCOVERY
[FIRST REQUEST]
Case No.: 2:17-cv-00085--JAD-CWH

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an Order extending the deadline for Hunt to file an opposition to Zuffa and White’s

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Motion to Stay Discovery until May 22, 2017.

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DATED: May 2, 2017

HIGGS FLETCHER & MACK LLP
By: /s/ Christina M. Denning
CHRISTINA M. DENNING, ESQ.
SCOTT J. INGOLD, ESQ.
Attorneys for Plaintiff
MARK HUNT

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DATED: May 2, 2017

CAMPBELL & WILLIAMS
By: /s/ J. Colby Williams
J. COLBY WILLIAMS, ESQ.
PHILIP R. ERWIN, ESQ.
Attorneys for Defendants ZUFFA, LLC
d/b/a ULTIMATE FIGHTING
CHAMPIONSHIP and DANA WHITE

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DATED: May 2, 2017

CHRISTIANSEN LAW OFFICES

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By: /s/ Kendelee L. Works
PETER S. CHRISTIANSEN, ESQ.
KENDELEE L. WORKS, ESQ.
Attorneys for Defendants BROCK
LESNAR

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IT IS SO ORDERED:

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BY: ____________________________________
UNITED STATES MAGISTRATE JUDGE

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May 4, 2017
DATED: ____________________________

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H IGGS F LE TCHER &
M ACK LLP
ATTO RNEY S AT LAW
SAN DIEGO

112567-00001
7953291.1

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STIPULATION AND [PROPOSED] ORDER RE:
EXTENSION TO FILE OPPOSITION TO MOTION TO STAY DISCOVERY
[FIRST REQUEST]
Case No.: 2:17-cv-00085--JAD-CWH

CERTIFICATE OF SERVICE

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Pursuant to Federal Rule of Civil Procedure 5 and the Court's Local Rules, the

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undersigned hereby certifies that on this day, May 2, 2017, a copy of the foregoing

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document entitled STIPULATION AND [PROPOSED] ORDER RE: EXTENSION

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OF TIME TO FILE OPPOSITION TO MOTION TO STAY

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[FIRST REQUEST] was filed and served through the Court's electronic filing system

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(CM/ECF) upon all registered parties and their counsel.

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Barbara Lodovice
An employee of Higgs Fletcher & Mack LLP

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iIGGS FLETCHER &
MACK LLP
ATTORNEYS AT LAW
SAN DIEGO

112567-00001
7953291.1

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STIPULATION AND [PROPOSED] ORDER RE:
EXTENSION TO FILE OPPOSITION TO MOTION TO STAY DISCOVERY
[FIRST REQUEST]
Case No.: 2:17-cv-00085--JAD-CWH