Roggio v. Costco Wholesale Corporation
Filing
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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
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PETER S. CHRISTIANSEN, ESQ.
Nevada Bar No. 5254
pete@christiansenlaw.com
R. TODD TERRY, ESQ.
Nevada Bar No. 6519
tterry@christiansenlaw.com
WHITNEY J. BARRETT, ESQ.
Nevada Bar No. 13662
whitney@christiansenlaw.com
CHRISTIANSEN LAW OFFICES
810 South Casino Center Blvd., Suite 104
Las Vegas, Nevada 89101
Telephone:
(702) 240-7979
Facsimile:
(866) 412-6992
Attorneys for Plaintiff
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810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax 866-412-6992
CHRISTIANSEN LAW OFFICES
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
TERESA I. ROGGIO, an Individual,
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CASE NO.
2:19-cv-01461-KJD-EJY
Plaintiff,
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STIPULATION AND [PROPOSED]
ORDER TO STAY THE CASE
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vs.
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COSTCO WHOLESALE CORPORATION, a
Foreign corporation, d/b/a COSTCO #737;
DOES I through X, inclusive; and ROE
BUSINESS ENTITIES XI through XX,
inclusive,
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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
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of resolving this matter. The settlement negotiations are ongoing, and the stay will permit the
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parties to continue and exhaust discussions culminating in a settlement agreement or trial.
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Currently, the parties have noticed several depositions but the Parties wish to avoid incurring
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additional costs and fees in order to accommodate settlement discussions.
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810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax 866-412-6992
CHRISTIANSEN LAW OFFICES
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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
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Rebuttal Expert Disclosure Deadline:
March 19, 2021
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Final Date for Dispositive Motions:
May 13, 2021
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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
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Case 2:19-cv-01461-KJD-EJY Document 22 Filed 01/06/21 Page 3 of 3
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ORDER
IT IS HEREBY ORDERED:
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In accordance with the stipulation of the parties, the Court orders as follows:
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Case Stayed Until:
February 19, 2021
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Final Joint Pre-Trial Order to be filed by:
April 20, 2021
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Close of Discovery:
April 14, 2021
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Initial Expert Disclosures Deadlines:
February 19, 2021
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Rebuttal Expert Disclosure Deadline:
March 19, 2021
Final Date for Dispositive Motions:
May 13, 2021
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810 S. Casino Center Boulevard, Suite 104
Las Vegas, Nevada 89101
702-240-7979 • Fax 866-412-6992
CHRISTIANSEN LAW OFFICES
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IT IS SO ORDERED this 6th day of January, 2021.
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___________________________________
UNITED STATES MAGISTRATE JUDGE
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Submitted by:
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CHRISTIANSEN LAW OFFICES
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_________________________
R. TODD TERRY, ESQ.
NV Bar No. 6519
810 S. Casino Center Blvd., Ste. 104
Las Vegas, NV 89101
Attorneys for Plaintiff
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