Snap Lock Industries, Inc. v. Swisstrax Corporation

Filing 119

ORDER granting 116 Stipulation; Telephonic Status Check set for 3/26/2019 at 10:00 AM in LV Chambers before Magistrate Judge Peggy A. Leen. Counsel shall contact Courtroom Deputy Jeff Miller at [phone] no later than 4:00 p.m. March 22, 2019. Signed by Magistrate Judge Peggy A. Leen on 3/14/2019. (Copies have been distributed pursuant to the NEF - JM)

Case 2:17-cv-02742-RFB-PAL Document 116 Filed 03/08/19 Page 1 of 4

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J. Stephen Peek
Nevada Bar No. 1758
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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Brett L. Foster (pro hac vice admission)
Tamara L. Kapaloski (pro hac vice admission)
DORSEY & WHITNEY LLP
111 S. Main Street Suite 2100
Salt Lake City, UT 84111-2176
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff Snap Lock Industries, Inc.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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SNAP LOCK INDUSTRIES, INC.,

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Plaintiff,
vs.
SWISSTRAX CORPORATION,

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Case No. 2:17-cv-02742-RFB-PAL
JOINT STIPULATED MOTION TO STAY
CASE DEADLINES PENDING
SETTLEMENT DISCUSSIONS AND
[PROPOSED] ORDER
(THIRD REQUEST)

Defendant.

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Plaintiff Snap Lock Industries, Inc. (“Snap Lock”) and Defendant Swisstrax Corporation

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(“Swisstrax”) (collectively, “Parties”), through their undersigned counsel, hereby respectfully jointly

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submit this Joint Stipulated Motion to Stay Case Deadlines Pending Settlement Discussions, and state

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as follows:

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1.

Currently pending before this Court is Snap Lock’s Emergency Motion for Protective

Order Regarding Subpoenas (“Motion for Protective Order”). See ECF No. 92.

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2.

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See ECF No. 106.

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4852-8165-9528\1

A hearing on the Motion for Protective Order is currently scheduled for March 12, 2019.

Case 2:17-cv-02742-RFB-PAL Document 116 Filed 03/08/19 Page 2 of 4

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3.

Also currently pending before this Court is Swisstrax’s Motion to Compel. See ECF

No. 102. The Motion to Compel is fully briefed, but a hearing on the motion has not been scheduled.
4.

The deadline for completing expert discovery in this case is April 30, 2019, and the

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deadline for filing dispositive motions is May 30, 2019. See ECF No. 115. The Parties will take a total

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of six expert depositions and anticipate that both Parties will file one or more dispositive motions.

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5.

The Parties have agreed to engage in a settlement conference or mediation within the

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next 60 days, to be completed by May 6, 2019, in an attempt to resolve this dispute. To allow the

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parties to dedicate their efforts to the potential settlement of this dispute, and to preserve judicial and

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party resources in the event that settlement negotiations dispose of the case, the parties hereby jointly

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request that the Court stay all case deadlines to allow the Parties to conduct a settlement conference or

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mediation. The Parties therefore respectfully request that the deadlines for completing expert discovery

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and for filing dispositive motions be stayed, pending the conclusion of the settlement conference or

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mediation by or on May 6, 2019. The Parties request that a status conference be scheduled for as soon

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as possible after May 6, 2019, regarding case deadlines in the event that the parties are unable to resolve

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this dispute.

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6.

The Parties do not currently have a trial date.

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7.

Good cause exists for this request. Staying the case deadlines will preserve the

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resources of both the Court and the parties in the event that the ongoing settlement negotiations dispose

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of this dispute. The Parties are not seeking the extensions for purposes of undue delay.

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Dated this 8th day of March, 2019.

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DORSEY & WHITNEY LLP

DICKINSON WRIGHT PLLC

/s/ Tamara L. Kapaloskika;jfdlkajdklfajdl
Brett L. Foster
Tamara L. Kapaloski
Dorsey & Whitney, LLP
111 South Main Street, Suite 2100
Salt Lake City, UT 84111-2176
Email: [e-mail]
Email: [e-mail]

/s/ Steven A. Caloiarodlka;jfdlkajdklfajdl
John L. Krieger
Steven A. Caloiaro
Christian T. Spaulding
8363 West Sunset Road, Suite 200
Las Vegas, NV 89113
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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4852-8165-9528\1

Case 2:17-cv-02742-RFB-PAL Document 116 Filed 03/08/19 Page 3 of 4

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IT IS SO ORDERED:
IT IS ORDERED that the parties' Stipulation (ECF No. 116) is GRANTED.
IT IS FURTHER ORDERED that a telephonic status check is set for 10:00 a.m.
____________________________________
March 26, 2019, to check on the status of Hon. Peggy A. Leen shall contact Courtroom
mediation. Counsel
Deputy Jeff Miller at [phone] no later than 4:00 p.m. March 22, 2019 to indicate
United States Magistrate Judge
a telephone number where counsel can be reached for the hearing.
DATED: ____________________________
Dated: March 14, 2019

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_______________________________
Peggy A. Leen
United States Magistrate Judge

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4852-8165-9528\1

Case 2:17-cv-02742-RFB-PAL Document 116 Filed 03/08/19 Page 4 of 4

CERTIFICATE OF SERVICE

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I hereby certify that on the 8th day of March, 2019, the foregoing JOINT STIPULATED

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MOTION TO STAY CASE DEADLINES PENDING SETTLEMENT DISCUSSIONS AND

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[PROPOSED] ORDER was served via e-mail upon the following:

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J. Stephen Peek
Nevada Bar No. 1758
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134
Phone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Plaintiff Snap Lock Industries, Inc.

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John L. Krieger
Steven A. Caloiaro
Christian T. Spaulding
DICKINSON WRIGHT PLLC
8363 West Sunset Road, Suite 200
Las Vegas, NV 89113-2210
[e-mail]
[e-mail]
cspaulding@ dickinsonwright.com

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Attorneys for Defendant Swisstrax Corporation

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/s/ Tamara L. Kapaloski

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4852-8165-9528\1