Torres v Alliance Plastics, LLC

Filing 16

ORDER granting 15 Stipulation; Discovery due by 10/31/2018. Motions due by 11/30/2018. Proposed Joint Pretrial Order due by 12/31/2018. Signed by Magistrate Judge Cam Ferenbach on 7/10/2018. (Copies have been distributed pursuant to the NEF - JM)

1
2
3
4
5
6
7

FISHER & PHILLIPS LLP
SCOTT M. MAHONEY, ESQ.
Nevada Bar No. 1099
HOLLY E. WALKER, ESQ.
Nevada Bar No. 14295
300 S. Fourth Street
Suite 1500
Las Vegas, NV 89101
Telephone: [phone]
E-mail Address: [e-mail]
[e-mail]
Attorneys for Defendant
Alliance Plastics, LLC

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA
11
300 S Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

10

OSVALDO TORRES,

12

Plaintiff,

13

v.
14
15

ALLIANCE PLASTICS, LLC,

)
)
)
)
)
)
)
)
)

Case No. 2:18-cv-0027-RFB-VCF

STIPULATION AND ORDER
TO EXTEND SCHEDULING
ORDER DEADLINES
(First Request)

17

Defendant.
____________________________________
The parties, by and through their respective counsel, hereby stipulate to extend

18

the Scheduling Order deadlines in this case as follows:

19

Discovery (Currently July 30, 2018):

October 31, 20181

Dispositive Motions (Currently August 29, 2018):

November 30, 2018

Joint Pretrial Order (Currently September 28, 2018):

December 31, 2018
or 30 days
from the ruling on a
dispositive motion

16

20
21
22
23
24
25
26
27
28

1

The discovery extension applies only to those depositions noticed before the end of the current discovery
deadline; a general extension for discovery is not sought.
-1-

FPDOCS 34265095.1

This is the first request for an extension of these deadlines. The parties provide

1
2

the following information to the Court regarding the proposed extension of the discovery

3

deadline.

4

Discovery Completed To Date

5
6

The parties have served their Initial Disclosures.

Defendant has served

interrogatories and requests for production, and Plaintiff has responded (although

7

Defendant believes some of the responses are deficient and intends to address these
8
9

deficiencies).
Remaining Discovery To Be Completed
Defendant has noticed Plaintiff’s deposition for July 23. Plaintiff has noticed a

11
300 S Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

10

12

24-subject FRCP 30(b)(6) deposition.

13

Reasons Discovery Could Not Be Completed Within The Existing Deadline

14

None of the witnesses who will be designated to respond to the Rule 30(b)(6)
15

deposition are believed to reside or work in Nevada, and travel arrangements must be
16
17

made. Plaintiff’s counsel and Defendant’s lead counsel are scheduled to participate in

18

the same arbitration hearing on August 14 and 15, 2018, and lead defense counsel has a

19

trial scheduled on a September 10 – October 12, 2018 trial stack, and additional time may

20

be needed to complete these depositions.

21

///

22

///
23
24

///

25
26
27
28
FPDOCS 34265095.1

-2-

Proposed Dates for Completion of Discovery

1
2
3
4
5
6
7
8
9

date of October 31, 2018.
Dated this 9th day of July 2018.
FISHER & PHILLIPS

KEMP & KEMP

By: /s/ Holly E. Walker, Esq.
Scott M. Mahoney, Esq.
Holly E. Walker, Esq.
300 S. Fourth Street
Suite 1500
Las Vegas, NV 89101
Attorneys for Defendant

By: /s/ James P. Kemp, Esq.
James P. Kemp, Esq.
7435 W. Azure Drive, Suite 110
Las Vegas, NV 89130
Attorneys for Plaintiff

11
300 S Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

10

The parties believe they will be able to complete discovery by the proposed new

IT IS SO ORDERED:

12

______________________________________
UNITED STATES MAGISTRATE JUDGE

13

7-10-2018
Dated:__________________________

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
FPDOCS 34265095.1

-3-