Hastings v. I.C. System, Inc. et al

Filing 32

ORDER Granting 30 Stipulation to Extend Time. Discovery Plan/Scheduling Order due by 8/18/2017. Signed by Magistrate Judge Nancy J. Koppe on 8/7/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01588-RFB-NJK Document 30 Filed 08/04/17 Page 1 of 3

1

6

ROBERT S. LARSEN, ESQ.
Nevada Bar No. 7785
WING Y. WONG, ESQ.
Nevada Bar No. 13622
GORDON REES SCULLY MANSUKHANI, LLP
300 South Fourth Street, Suite 1550
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]

7

Attorneys for I.C. System, Inc.

2
3
4
5

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA
JOHN HASTINGS,

11
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

10

)
)
)
)
)
)
)
)
)
)
)
)
)

Plaintiff,

12

vs.

13

I.C. SYSTEM, INC.; and DOES 1-10,

14

Defendants.

15
16

Case No.: 2:17-CV-01588-RFB-NJK

STIPULATION AND ORDER TO
EXTEND TIME TO FILE
DISCOVERY PLAN
FIRST REQUEST

17
18
19
20

Pursuant to LR IA 6-1 and LR 7-1, Plaintiff John Hastings (“Plaintiff”), and Defendant
I.C. System, Inc. (“ICS”), by and through their respective attorneys of record, stipulate as
follows:
STIPULATION

21
22
23
24
25
26
27
28

1.

Plaintiff filed his Complaint on September 27, 2016 in the Northern District of

Illinois.
2.

The case was subsequently transferred to the District of Nevada. ECF No. 25.

3.

On June 8, 2017, this Court issued a Minute Order requesting the parties file a

discovery plan by August 4, 2017. ECF No. 27.
4.

It appears that the Court may have mailed notice of the June 8, 2017 Minute

Order [ECF No. 27] to ICS’s attorneys Gordon Rees Scully Mansukhani, LLP in Illinois and
-1-

Case 2:17-cv-01588-RFB-NJK Document 30 Filed 08/04/17 Page 2 of 3

1

California, however, Gordon Rees Scully Mansukhani, LLP does not have record of having

2

received the Minute Order [ECF No. 27].

3
4

5.

4, 2017 from the Plaintiff’s attorneys.

5
6

Gordon Rees Scully Mansukhani, LLP learned about the Minute Order on August

6.

Due to a calendaring error, Plaintiff’s attorneys, Lemberg Law L.L.C., did not

realize the due date for the discovery plan was August 4, 2017 until August 4, 2017.

7

7.

Due to the calendaring error, Plaintiff’s attorneys were unable to provide a copy

8

of the draft discovery plan until August 4, 2017, the date on which the discovery plan is due to

9

the Court under ECF No. 27.
8.

Plaintiff’s attorneys are also preparing a pro hac vice application to allow them to

11
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

10

appear in this action. Plaintiff has secured local Nevada counsel and Plaintiff’s attorneys intend

12

to file the pro hac vice application with the Court shortly.

13
14

9.

discovery plan.

15
16

Due to these reasons, the parties request a two week extension to file the

10.

The extension will allow the parties to review the draft discovery plan and more

fully discuss potential issues regarding document production, protective orders, etc.

17

11.

Plaintiff and ICS are also currently engaged in settlement discussions to resolve

18

this case. An extension of the deadline to submit the discovery plan will allow the parties to

19

continue settlement discussions without incurring additional fees and expenses.

20

12.

This is the parties’ first request to continue the deadline to submit the discovery

21

plan and this request is not made for improper purposes or to delay the case.

22

///

23

///

24

///

25

///

26

///

27

///

28

///
-2-

Case 2:17-cv-01588-RFB-NJK Document 30 Filed 08/04/17 Page 3 of 3

1
2

13.

Therefore, the parties request that the deadline to submit the discovery plan be

extended until August 18, 2017.

3
DATED: August 4, 2017.

DATED: August 4, 2017.

GORDON REES SCULLY
MANSUKHANI, LLP

LEMBERG LAW, L.L.C

5
6

/s/ Robert S. Larsen

/s/ Jenny DeFrancisco

7

ROBERT S. LARSEN, ESQ.
Nevada Bar No. 7785
WING Y. WONG, ESQ.
Nevada Bar No. 13622
300 South Fourth Street, Suite 1550
Las Vegas, Nevada 89101
Attorneys for I.C. System, Inc.

JENNY DEFRANCISCO, ESQ.
Pro Hac Vice forthcoming
43 Danbury Rd. 3rd Floor
Wilton, CT 06897
Attorneys for Plaintiff John Hastings

4

8
9

11
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

10

12
ORDER
13
IT IS SO ORDERED.
14
15
16

UNITED STATES MAGISTRATE JUDGE
August 7, 2017
DATED:

17
18
19
20
21
22
23
24
25
26
27

1132409/34053893v.2

28
-3-