Composite Resources Inc v. Recon Medical LLC

Filing 169

ORDER granting ECF No. 168 Stipulation to Extend Time. Joint Pretrial Order due by 12/20/2019. Signed by Magistrate Judge Cam Ferenbach on 11/21/2019. (Copies have been distributed pursuant to the NEF - LH)

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1 2 3 4 V.R. Bohman, Esq. Nevada Bar No. 13075 SNELL & WILMER L.L.P. 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 Telephone: 702.784.5200 Facsimile: 702.784.5252 Email: vbohman@swlaw.com 5 6 7 8 Sid Leach, Esq. (Admitted Pro Hac Vice) SNELL & WILMER L.L.P. 2400 E. Van Buren – One Arizona Center Phoenix, Arizona 85004 Telephone: 602.382.6000 Facsimile: 602.382.0430 Email: sleach@swlaw.com 9 10 Snell & Wilmer L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 11 12 William Y. Klett, III, Esq. (Admitted Pro Hac Vice) BURR FORMAN MCNAIR 1221 Main Street, Suite 1800 Columbia, South Carolina 29201 Telephone: 803.753.321 Facsimile: 803.753.3278 Email: wklett@burr.com 13 Attorneys for Plaintiff Composite Resources, Inc. 14 UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA 16 17 COMPOSITE RESOURCES, INC., Case No. 2:17-cv-01755-MMD-VCF 18 Plaintiff, STIPULATION AND ORDER TO EXTEND JOINT PRETRIAL ORDER DEADLINE 19 vs. 20 RECON MEDICAL, LLC, (THIRD REQUEST) 21 22 23 24 25 26 27 28 Defendant. This is the parties’ third stipulation to extend the deadline to file their Joint Pretrial Order. Pursuant to LR IA 6-1 and LR 26-4, Plaintiff Composite Resources, Inc. (“CRI”) and Defendant Recon Medical, LLC (“Recon” and together with CRI the “Parties”), by and through their respective counsel, for good cause as discussed below, hereby stipulate and agree to extend the Joint Pretrial Order deadline presently set in this matter to December 20, 2019. 1 A. 2 3 Good Cause Exists for the Requested Extension in this Patent Litigation The Joint Pretrial Order deadline is presently set for November 22, 2019. ECF No. 167. The Parties have been diligent in preparing the Joint Pretrial Order including: 4  On October 21, 2019 the Parties exchanged deposition designations; 5  On October 24 CRI circulated its first draft of the Joint Pretrial Order, with space 6 provided for Recon’s portions;  7 8 designations and exhibits found in the Joint Pretrial Order;  9 10 L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 On November 18 Recon circulated its redline of the Joint Pretrial Order, resulting in the first full draft of the Joint Pretrial Order;  11 Snell & Wilmer On November 14 Recon circulated its exhibit list and objections to CRI’s deposition 12 On November 20 CRI’s counsel requested a meet-and-confer regarding Recon’s revised Joint Pretrial Order;  13 The Parties met and conferred on November 21 and agreed that additional discussion 14 and revision of Joint Pretrial Order would enable substantial enhancement of the Joint 15 Pretrial Order. 16 Accordingly, extending the Joint Pretrial Order deadline will allow counsel to provide the 17 Court a superior pretrial order, serve the Court’s purposes under Federal Rule of Civil 18 Procedure 1 as well as judicial efficiency, and will not delay or otherwise impact the trial date as 19 no trial date has been set. 20 B. 21 Proposed Deadlines 1. Pretrial Order Cut-Off Date: 22 Current Deadline: November 22, 2019 23 Proposed: December 20, 2019 24 C. Conclusion 25 The Parties respectfully submit that good cause exists for an extension of the Joint Pretrial 26 Order deadline as stated herein, and it is not sought for purposes of undue delay. Further, the 27 extension sought will not impact the trial as a trial date has not yet been set. Accordingly, the 28 -2- 1 Parties respectfully request that the Court extend the Joint Pretrial Order deadline as requested 2 above. 3 4 5 6 ORDER IT IS SO ORDERED. The Parties’ Joint Pretrial Order deadline is extended to December 20, 2019. Dated this 21st day of November, 2019. 7 8 Cam Ferenbach United States Magistrate Judge 9 10 Snell & Wilmer L.L.P. LAW OFFICES 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 702.784.5200 11 12 IT IS SO STIPULATED Dated: November 21, 2019. Dated: November 21, 2019. DENKO & BUSTAMANTE LLP SNELL & WILMER L.L.P. 13 14 15 16 17 18 19 By /s/ John Bustamante J. Scott Denko, Esq. John M. Bustamante, Esq. 2905 San Gabriel Street, Ste. 205 Austin, Texas 78705 By: /s/ V.R. Bohman Sid Leach, Esq. V.R. Bohman, Esq. 3883 Howard Hughes Parkway, Suite 1100 Las Vegas, Nevada 89169 Edmond “Buddy” Miller, Esq. 1610 Montclair Avenue, Suite C Reno, NV 89509 Attorneys for Defendant/Counterclaimant Recon Medical, LLC William Y. Klett, III, Esq. BURR FORMAN MCNAIR 1221 Main Street, Suite 1800 Columbia, South Carolina 29201 Attorneys for Plaintiff Composite Resources, Inc. 20 21 22 23 4825-2516-6765 24 25 26 27 28 -3-

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