Focalpoint International Inc. v. Dom Rubino Consulting Services Inc. et al

Filing 39

ORDER granting 38 Stipulation. Discovery due by 11/19/2018. Motions due by 12/21/2018. Proposed Joint Pretrial Order due by 1/18/2019. Signed by Magistrate Judge Peggy A. Leen on 7/23/2018. (Copies have been distributed pursuant to the NEF - MMM)

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Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 1 of 4 1 2 3 4 5 6 7 JACOB D. BUNDICK, ESQ. Nevada Bar No. 9772 GREENBERG TRAURIG, LLP 3773 Howard Hughes Parkway, Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 Email: bundickj@gtlaw.com Counsel for Plaintiff FocalPoint International, Inc. 8 9 10 11 UNITED STATES DISTRICT COURT 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 GREENBERG TRAURIG, LLP 12 DISTRICT OF NEVADA 13 14 Case No.: 2:18-cv-00236-APG-PAL FOCALPOINT INTERNATIONAL, INC., Plaintiff, 15 STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES 16 vs. 17 DOM RUBINO CONSULTING SERVICES, INC.; and BIZSTRATPLAN, INC., 18 [FIRST REQUEST] Defendants. 19 20 21 Plaintiff, FocalPoint International, Inc. (“FocalPoint”), and Defendants Dom Rubino 22 Consulting Services, Inc. (“DRCS”) and BizStratPlan Inc. (“BizStratPlan”) (collectively, the 23 “Parties”), by and through their respective counsel of record, and pursuant to Local Rules 7-1 and 24 26-4, hereby stipulate and agree to extend the deadlines contained in the Discovery Plan and 25 Scheduling Order [Doc. 27] for a period of 60 days for the reasons set forth herein. 26 I. DISCOVERY COMPLETED TO DATE 27 The Parties have each submitted their initial disclosures. On April 20, 2018, Defendants 28 served their Initial Disclosures Pursuant to FRCP 26(a)(1). On May 24, 2018, FocalPoint Served its 1 CHI 69382885v1 Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 2 of 4 1 Initial Disclosures Pursuant to FRCP 26(a)(1). On June 22, 2018, FocalPoint served its First 2 Supplemental Disclosures. On July 2, 2018, FocalPoint served its Second and Third Supplemental 3 Disclosures. 4 The Parties have also served written discovery. On June 1, 2018, Defendants served 5 Requests for Production on FocalPoint. FocalPoint provided its initial response to these Requests on 6 July 2, 2018. Efforts to complete its response remain ongoing. On June 22, 2018, FocalPoint served 7 its First Set of Interrogatories and First Set of Document Requests on both DRCS and BizStratPlan. 8 Defendants’ efforts to respond to these discovery requests remain ongoing. 9 II. REASONS FOR EXTENDING DEADLINES; GOOD CAUSE discovery requests and resolve the case. However, given some unforeseen circumstances, including 12 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 The Parties have made reasonable efforts in good faith to respond to the respective 11 GREENBERG TRAURIG, LLP 10 the Parties’ ongoing settlement discussions and the recent addition of a third-party, the Parties have 13 determined that they need a limited extension to allow for full development of the record. The 14 Parties’ joint request to extend the deadlines in this matter is made in good faith and good cause 15 exists for such an extension. This request is not made for purposes of delay. 16 III. PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY 17 Event Current Deadline Proposed New Deadline 18 Discovery cutoff September 18, 2018 November 19, 2018 19 Deadline to amend pleadings June 20, 2018 August 20, 2018 20 Deadline for Interim Status Report July 20, 2018 September 21, 2018 21 Deadline to make initial expert disclosures July 20, 2018 September 21, 2018 Deadline to make rebuttal expert disclosures August 20, 2018 October 19, 2018 Deadline to file dispositive motions October 18, 2018 December 21, 2018 Deadline to file joint pretrial order November 19, 2018 January 18, 2019 22 23 24 25 26 27 /// 28 /// 2 CHI 69382885v1 Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 3 of 4 1 Based on the foregoing stipulation and good cause appearing, the Parties respectfully request 2 that the Court enter an Order adopting the Parties’ proposed schedule for completing all remaining 3 discovery and deadlines. 4 IT IS SO STIPULATED. 5 DATED this 17th day of July, 2018. DATED this 17th day of July, 2018. 6 GREENBERG TRAURIG, LLP LEWIS ROCA ROTHGERBER CHRISTIE LLP /s/ Jacob D. Bundick JACOB D. BUNDICK, ESQ. Nevada Bar No. 9772 3773 Howard Hughes Parkway, Suite 400 N Las Vegas, NV 89169 /s/ Dan R. Waite DAN R. WAITE, ESQ. Nevada Bar No. 4078 ERIK J. FOLEY, ESQ. Nevada Bar No. 14195 3993 Howard Hughes Parkway, Suite 600 Las Vegas, NV 89169 7 8 9 10 11 Counsel for Plaintiff FocalPoint International, Inc. Counsel for Defendants Dom Rubino Consulting Services, Inc. and BizStratPlan, Inc. 3773 Howard Hughes Parkway Suite 400 North Las Vegas, Nevada 89169 Telephone: (702) 792-3773 Facsimile: (702) 792-9002 GREENBERG TRAURIG, LLP 12 13 14 15 16 IT IS SO ORDERED this 23rd day of July, 2018. 17 18 UNITED STATES DISTRICT JUDGE / UNITED STATES MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 28 3 CHI 69382885v1

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