Focalpoint International Inc. v. Dom Rubino Consulting Services Inc. et al
Filing
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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)
Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 1 of 4
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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.
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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
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DISTRICT OF NEVADA
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Case No.: 2:18-cv-00236-APG-PAL
FOCALPOINT INTERNATIONAL, INC.,
Plaintiff,
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STIPULATION AND ORDER TO EXTEND
DISCOVERY DEADLINES
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vs.
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DOM RUBINO CONSULTING SERVICES,
INC.; and BIZSTRATPLAN, INC.,
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[FIRST REQUEST]
Defendants.
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Plaintiff, FocalPoint International, Inc. (“FocalPoint”), and Defendants Dom Rubino
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Consulting Services, Inc. (“DRCS”) and BizStratPlan Inc. (“BizStratPlan”) (collectively, the
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“Parties”), by and through their respective counsel of record, and pursuant to Local Rules 7-1 and
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26-4, hereby stipulate and agree to extend the deadlines contained in the Discovery Plan and
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Scheduling Order [Doc. 27] for a period of 60 days for the reasons set forth herein.
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I.
DISCOVERY COMPLETED TO DATE
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The Parties have each submitted their initial disclosures. On April 20, 2018, Defendants
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served their Initial Disclosures Pursuant to FRCP 26(a)(1). On May 24, 2018, FocalPoint Served its
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Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 2 of 4
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Initial Disclosures Pursuant to FRCP 26(a)(1). On June 22, 2018, FocalPoint served its First
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Supplemental Disclosures. On July 2, 2018, FocalPoint served its Second and Third Supplemental
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Disclosures.
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The Parties have also served written discovery. On June 1, 2018, Defendants served
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Requests for Production on FocalPoint. FocalPoint provided its initial response to these Requests on
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July 2, 2018. Efforts to complete its response remain ongoing. On June 22, 2018, FocalPoint served
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its First Set of Interrogatories and First Set of Document Requests on both DRCS and BizStratPlan.
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Defendants’ efforts to respond to these discovery requests remain ongoing.
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II.
REASONS FOR EXTENDING DEADLINES; GOOD CAUSE
discovery requests and resolve the case. However, given some unforeseen circumstances, including
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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
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GREENBERG TRAURIG, LLP
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the Parties’ ongoing settlement discussions and the recent addition of a third-party, the Parties have
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determined that they need a limited extension to allow for full development of the record. The
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Parties’ joint request to extend the deadlines in this matter is made in good faith and good cause
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exists for such an extension. This request is not made for purposes of delay.
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III.
PROPOSED SCHEDULE FOR COMPLETING ALL REMAINING DISCOVERY
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Event
Current Deadline
Proposed New Deadline
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Discovery cutoff
September 18, 2018
November 19, 2018
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Deadline to amend pleadings
June 20, 2018
August 20, 2018
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Deadline for Interim Status Report
July 20, 2018
September 21, 2018
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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
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///
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///
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Case 2:18-cv-00236-APG-PAL Document 38 Filed 07/17/18 Page 3 of 4
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Based on the foregoing stipulation and good cause appearing, the Parties respectfully request
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that the Court enter an Order adopting the Parties’ proposed schedule for completing all remaining
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discovery and deadlines.
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IT IS SO STIPULATED.
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DATED this 17th day of July, 2018.
DATED this 17th day of July, 2018.
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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
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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
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IT IS SO ORDERED this 23rd day of July, 2018.
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UNITED STATES DISTRICT JUDGE /
UNITED STATES MAGISTRATE JUDGE
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