Snap Lock Industries, Inc. v. Swisstrax Corporation

Filing 155

ORDER granting 154 STIPULATION FOR EXTENSION OF TIME (Second Request) re Case Management Deadlines as to 153 Order. Discovery due by 6/26/2020. Motions due by 7/27/2020. Proposed Joint Pretrial Order due by 8/26/2020. Signed by Magistrate Judge Brenda Weksler on 4/8/2020. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:17-cv-02742-RFB-BNW Document 154 Filed 04/07/20 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-BNW
STIPULATION FOR EXTENSION OF
CASE MANAGEMENT DEADLINES FOR
CONDUCTING DEPOSITIONS
(SECOND 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 stipulate and agree

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to extend certain case management deadlines, as set forth more fully below.

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1.

Although the parties scheduled all expert depositions in this case prior to the March 13,

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2020, deadline for conducting expert discovery, and completed two expert depositions prior to the

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deadline, based on travel restrictions in effect due to the Covid-19 pandemic and the parties’ and expert

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witnesses’ concern regarding travel, the parties agreed to continue the depositions and requested an

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additional 45 days to complete expert discovery. See ECF No. 152.

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4852-8165-9528\1

Case 2:17-cv-02742-RFB-BNW Document 154 Filed 04/07/20 Page 2 of 4

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2.

On March 13, 2020, the Court granted the Parties’ Stipulation and extended certain case

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management deadlines, including extending the last day to complete expert discovery to April 27,

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2020. See ECF No. 153.

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3.

Unfortunately, since that time, the restrictions and concerns regarding the Covid-19

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pandemic have only intensified and the states where the expert witnesses and counsel for the parties

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reside are all under stay-at-home directives or mandatory stay-at-home orders. In addition, some of

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the expert witnesses lack technology for video-conferencing, making preparing for and taking remote

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depositions difficult. Moreover, if certain of the experts are required to travel for depositions, they

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may be in violation of State executive orders. Due to these restrictions, and the parties’ and witnesses’

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concern regarding the virus, the parties hereby request an additional sixty (60) days to complete expert

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discovery. The parties are working together to reschedule the four remaining expert depositions within

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the newly extended expert discovery deadline. The parties also agree to extend the dispositive motion

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deadline and the date to file the joint pretrial order to maintain the timing of the deadlines following

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the close of expert discovery. Accordingly, the parties respectfully request that the Court enter an

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Order regarding case deadlines as follows:

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DEADLINE

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Last day to complete expert April 27, 2020

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discovery

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Dispositive motion deadline

May 27, 2020

July 27, 2020

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Date to file joint pretrial order

June 29, 2020

August 26, 2020

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4.

CURRENT DATE

PROPOSED DATE
June 26, 2020

The Parties do not currently have a trial date. Good cause exists for this request. The

Parties are not seeking the continuance for purposes of undue delay.
5.

Pursuant to the initial Scheduling Order in this case (ECF No. 59), in the event

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dispositive motions are filed, the date for filing the joint pretrial order shall be suspended until 30 days

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after a decision on the dispositive motions. In addition, the disclosures required by Fed. R. Civ. P.

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26(a)(3), and any objections thereto, shall be included in the pretrial order (id.).

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Case 2:17-cv-02742-RFB-BNW Document 154 Filed 04/07/20 Page 3 of 4

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Dated this 7th day of April, 2020.

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DORSEY & WHITNEY LLP

DICKINSON WRIGHT PLLC

/s/;Tamara L. Kapaloskijfdlkajdklfajdl
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/;John L. Kriegerjfdlkajdklfajdl
John L. Krieger
Steven A. Caloiaro
8363 West Sunset Road, Suite 200
Las Vegas, NV 89113
Email: [e-mail]
Email: [e-mail]

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IT IS SO ORDERED:
____________________________________
Hon. Brenda Weksler
United States Magistrate Judge
4/8/2020
DATED: ____________________________

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Case 2:17-cv-02742-RFB-BNW Document 154 Filed 04/07/20 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on the 7th day of April, 2020, the foregoing STIPULATION FOR

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EXTENSION OF CASE MANAGEMENT DEADLINES FOR CONDUCTING

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DEPOSITIONS was served to all counsel of record via the Court’s CM/ECF system.

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/s/ Tamara L. Kapaloski

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