Reed v. Convergent Outsourcing, Inc. et al

Filing 22

ORDER Granting 21 First Stipulation for Extension of Time re Discovery Deadlines. Discovery due by 12/3/2018. Motions due by 1/2/2019. Proposed Joint Pretrial Order due by 2/3/2019. Signed by Magistrate Judge Carl W. Hoffman on 8/3/2018. (Copies have been distributed pursuant to the NEF - SLD)

1 VERNON A. NELSON, JR., ESQ.
Nevada Bar No.: 6434
2 MELISSA INGLEBY, ESQ.
Nevada Bar No.: 12935
3 THE LAW OFFICE OF VERNON NELSON
9480 S. Eastern Avenue, Suite 252
4 Las Vegas, Nevada 89123
Tel.: [phone]
5 Fax.: [phone]
[e-mail]
6 [e-mail]
Attorneys for Plaintiff Robert Reed
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Case No.: 2:18-cv-00146-JAD-CWH
Plaintiff,

12 v.
ATTORNEY AT LAW

THE LAW OFFICE OF VERNON NELSON

10 ROBERT REED,

13 CONVERGENT OUTSOURCING, INC. and
COMCAST ENTERPRISE SERVICES, LLC.,
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Defendants.
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STIPULATION FOR EXTENSION
OF DISCOVERY DEADLINES
[First Request]

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Pursuant to LR 6-1 and LR 26-4, the parties, by and through their respective counsel of
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record, hereby stipulate and request that this Court extend discovery in the above-captioned case
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ninety (90) days, up to and including December 4, 2018. In addition, the parties request that the
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dispositive motions and pretrial order deadlines be extended for an additional ninety (90) days, as
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outlined herein. In support of this Stipulation and Request, the parties state as follows:
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A.

Discovery Completed to Date.

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1. Plaintiff filed his Complaint on January 26, 2018.
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2. Defendant Comcast Enterprise Services, LLC filed its Answer on March 6,2018.
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3. Defendant Convergent Outsourcing, Inc. filed its Answer on March 22, 2018.
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4. Defendant Comcast Enterprise Services, LLC served its initial disclosure on April
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13, 2018.
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5. Defendant Convergent Outsourcing, Inc. served its initial disclosure on April 20,
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2018.

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6. Plaintiff Robert Reed served his initial disclosure on May 20, 2018.
B.

Specific Description of Discovery that Remains to be Completed.

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1. Completion of written discovery and document productions.

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2. Depositions of Plaintiff, Defendant Convergent Outsourcing, Inc., and Defendant

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Comcast Enterprise Services, LLC.

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3. Depositions of any remaining witnesses.

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C.

Reasons Why the Remaining Discovery was not Completed.

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The parties aver, pursuant to LR6-1, good cause exists for requested extension. The

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parties have been, and continue to make diligent efforts to settle this matter. The parties

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agree the current deadlines restrict all parties from potentially settling this matter and

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conducting the remaining necessary discovery.

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D.

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Event

Current Deadline

Proposed New Deadline

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Close of Discovery

September 4, 2018

December 3, 2018

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Dispositive Motions

October 4, 2018

January 2, 2019

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Pretrial Order

November 5, 2018

February 3, 2019

Proposed Discovery Deadlines.

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IT IS SO STIPULATED THIS 16th day of July, 2018.
Dated this 17th day of July, 2018.

Dated this 17th day of July, 2018.

THE LAW OFFICE OF VERNON NELSON

SPRINKEL & FINK

/s/ Melissa Ingleby
VERNON A. NELSON, JR., ESQ.
Nevada Bar No.: 6434
MELISSA INGLEBY, ESQ.
Nevada Bar No. 12935
9480 S. Eastern Ave., Ste. 252
Las Vegas, NV 89123
Attorneys for Plaintiff Robert Reed

/s/ Jonathan C. Pattillo
LEONARD T. FINK, ESQ.
Nevada Bar No. 6296
JONATHAN C. PATTILLO, ESQ.
Nevada Bar No. 13929
10655 Park Run Drive, Suite 275
Las Vegas, NV 89144
Attorneys for Defendant Convergent
Outsourcing, Inc.

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Dated this 17th day of July, 2018.

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CLARK HILL PLLC
/s/ Jeremy Thompson
JEREMY THOMPSON, ESQ.
Nevada Bar No. 12503
3800 Howard Hughes Pkwy., Ste. 500
Las Vegas, NV 89169
Attorney for Defendant Comcast Enterprise
Services, LLC

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ORDER

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IT IS SO ORDERED.

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Dated: August 3, 2018

__________________________
UNITED STATES MAGISTRATE JUDGE

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Case No.: 2:18-cv-00146-JAD-CWH

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