Roggio v. Costco Wholesale Corporation

Filing 22

ORDER granting 21 Stipulation to Stay Case until 2/19/2021. Discovery due by 4/14/2021. Proposed Joint Pretrial Order due by 4/20/2021. Motions due by 5/13/2021. Signed by Magistrate Judge Elayna J. Youchah on 1/6/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:19-cv-01461-KJD-EJY Document 22 Filed 01/06/21 Page 1 of 3

1
2
3
4
5
6
7
8

PETER S. CHRISTIANSEN, ESQ.
Nevada Bar No. 5254
[e-mail]
R. TODD TERRY, ESQ.
Nevada Bar No. 6519
[e-mail]
WHITNEY J. BARRETT, ESQ.
Nevada Bar No. 13662
[e-mail]
CHRISTIANSEN LAW OFFICES
810 South Casino Center Blvd., Suite 104
Las Vegas, Nevada 89101
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff

10
810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax [phone]

CHRISTIANSEN LAW OFFICES

9
UNITED STATES DISTRICT COURT

11
12

DISTRICT OF NEVADA
TERESA I. ROGGIO, an Individual,

13

CASE NO.

2:19-cv-01461-KJD-EJY

Plaintiff,

14

STIPULATION AND [PROPOSED]
ORDER TO STAY THE CASE

15

vs.

16

COSTCO WHOLESALE CORPORATION, a
Foreign corporation, d/b/a COSTCO #737;
DOES I through X, inclusive; and ROE
BUSINESS ENTITIES XI through XX,
inclusive,

17
18
19
20
21
22
23
24
25
26
27
28

Defendants.
Pursuant to Local Rules 6-1 and 26-4, the parties, by and through their respective attorneys
of record, stipulate and agree to stay the pendency of this case by forty-five (45) days, to continue
the deadline for the parties to file their Joint Pre-Trial order an additional sixty (60) days, and to
extend discovery deadlines an additional thirty (30) days.
This is the first request for an extension for the parties to complete the Joint Pre-Trial
Order. The Joint Pre-Trial Order is currently due on March 12, 2021. This Stipulation is sought
by the parties in order to allow for substantive settlement negotiations to continue with the hopes

Case 2:19-cv-01461-KJD-EJY Document 22 Filed 01/06/21 Page 2 of 3

1

of resolving this matter. The settlement negotiations are ongoing, and the stay will permit the

2

parties to continue and exhaust discussions culminating in a settlement agreement or trial.

3

Currently, the parties have noticed several depositions but the Parties wish to avoid incurring

4

additional costs and fees in order to accommodate settlement discussions.

5
6
7
8

10
810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax [phone]

CHRISTIANSEN LAW OFFICES

9

For this reason, and in order to avoid potentially unnecessary additional fees and costs if
this matter settles, the parties hereby stipulate stay this case forty-five (45) days, or February 19,
2021 and continue the deadline for the parties to submit their Joint Pre-Trial order an additional
sixty (60) days from the date the stay expires, or until April 20, 2021.
Accordingly, the parties have agreed and stipulated to the following deadlines:
Case Stayed Until:

February 19, 2021

Final Joint Pre-Trial Order to be filed by:

April 20, 2021

Close of Discovery:

April 14, 2021

Initial Expert Disclosures Deadlines:

February 19, 2021

15

Rebuttal Expert Disclosure Deadline:

March 19, 2021

16

Final Date for Dispositive Motions:

May 13, 2021

11
12
13
14

17
18
19

DATED this 5th day of January, 2021

DATED this 5th day of January, 2021

CHRISTIANSEN LAW OFFICES

OLSON, CANNON, GORMLEY, ANGULO
& STOBERSKI

By________________________
PETER S. CHRISTIANSEN, ESQ.
NV Bar No. 5254
R. TODD TERRY, ESQ.
NV Bar No. 6519
WHITNEY J. BARRETT, ESQ.
NV Bar No. 13662
810 S. Casino Center Blvd., Ste. 104
Las Vegas, NV 89101
Attorneys for Plaintiff

By /s/ Michael A. Federico, Esq.
MICHAEL A. FEDERICO, ESQ.
NV Bar No. 5946
9950 W. Cheyenne Avenue
Las Vegas, NV 89129
Attorneys for Defendant Costco Wholesale

20
21
22
23
24
25
26
27
28

2

Case 2:19-cv-01461-KJD-EJY Document 22 Filed 01/06/21 Page 3 of 3

1
2

ORDER
IT IS HEREBY ORDERED:

3

In accordance with the stipulation of the parties, the Court orders as follows:

4

Case Stayed Until:

February 19, 2021

5

Final Joint Pre-Trial Order to be filed by:

April 20, 2021

6

Close of Discovery:

April 14, 2021

7

Initial Expert Disclosures Deadlines:

February 19, 2021

8

Rebuttal Expert Disclosure Deadline:

March 19, 2021

Final Date for Dispositive Motions:

May 13, 2021

10
810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax [phone]

CHRISTIANSEN LAW OFFICES

9

IT IS SO ORDERED this 6th day of January, 2021.

11
12
13

___________________________________
UNITED STATES MAGISTRATE JUDGE

14
15

Submitted by:

16

CHRISTIANSEN LAW OFFICES

17
18
19
20
21

_________________________
R. TODD TERRY, ESQ.
NV Bar No. 6519
810 S. Casino Center Blvd., Ste. 104
Las Vegas, NV 89101
Attorneys for Plaintiff

22
23
24
25
26
27
28

3