Fischer v. Full Spectrum Laser LLC

Filing 32

ORDER granting 31 Stipulation - Discovery due by 10/18/2021. Motions due by 11/17/2021. Proposed Joint Pretrial Order due by 12/17/2021. Signed by Magistrate Judge Daniel J. Albregts on 9/8/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:20-cv-00339-APG-DJA Document 31 Filed 09/07/21 Page 1 of 3
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09/08/21

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FISHER & PHILLIPS LLP
LISA A. MCCLANE, ESQ.
Nevada Bar No. 10139
BRIAN L. BRADFORD, ESQ.
Nevada Bar No. 9518
300 S. Fourth Street
Suite 1500
Las Vegas, NV 89101
Telephone: [phone]
E-Mail Address: [e-mail]
E-Mail Address: [e-mail]
Attorneys for Defendant, Full Spectrum Laser LLC

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UNITED STATES DISTRICT COURT

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300 S. Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

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DISTRICT OF NEVADA
FREDERICK SCOTT FISCHER,

) Case No. 2:20-cv-00339-APG-DJA
)
) STIPULATION AND ORDER TO
Plaintiff,
)
EXTEND DISCOVERY
v.
)
)
(Sixth Request)
FULL SPECTUM LASER LLC,
)
)
)
Defendant.
___________________________________ )

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IT IS HEREBY STIPULATED AND AGREED, by and between the parties’

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counsel of record, that discovery deadlines in the Scheduling Order (ECF No. 30) be

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extended thirty-one (31) days for the express purpose of completing remaining

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depositions as follows:

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Plaintiff’s Deposition

September 20, 2021

Defendant’s 30(b)(6) Deposition

September 29, 2021

Accordingly, the parties are also requesting the following deadlines also be modified:

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Discovery Deadline

October 18, 2021

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Dispositive Motion Deadline

November 17, 2021

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Joint Pretrial Order

December 17, 2021

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FP 41566857.1

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Case 2:20-cv-00339-APG-DJA Document 31 Filed 09/07/21 Page 2 of 3
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09/08/21

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This is the sixth request for an extension of these deadlines. The parties provide
the following information to the Court regarding the proposed extension of the
discovery deadline. The reason for the parties’ inability to comply with this deadline is
Defendant’s counsel’s previously unforeseeable medical leave.
Discovery Completed To Date

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The parties have exchanged disclosures and written discovery. The motion to

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compel which was before the Court, has been mostly resolved, and the parties have

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scheduled depositions.

300 S. Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

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Remaining Discovery To Be Completed

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The parties have scheduled the Plaintiff’s deposition for September 20, 2021,

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and Defendant’s 30(b)(6) deposition tentatively for September 29, 2021.
Reasons Discovery Could Not Be Completed Within The Existing Deadline

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The parties continue to make progress in this matter, but Defendant’s counsel

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was out on a medical leave of absence and just returned September 1. Scheduling

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conflicts made it difficult to find mutually agreeable dates for deposition within the

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short time remaining before the close of the current discovery deadline. This extension
will allow the parties to conduct depositions prior to the close of the proposed
///

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///

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///

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///

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///
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FP 41566857.1

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Case 2:20-cv-00339-APG-DJA Document 31 Filed 09/07/21 Page 3 of 3
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09/08/21

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This is the parties’ sixth request for an extension of the discovery deadline date

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and is not made to delay this matter. Based upon the foregoing, the parties believe

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there is good cause for the requested extension.

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Dated this 7th day of September, 2021.

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FISHER & PHILLIPS LLP

THE VERSTANDIG LAW FIRM, LLC

/s/ Lisa A. McClane, Esq.
LISA A. MCCLANE, ESQ.
BRIAN L. BRADFORD, ESQ.
300 South Fourth Street
Suite 1500
Las Vegas, Nevada 89101
Attorneys for Defendant
Full Spectrum Laser LLC

/s/ Maurice VerStandig, Esq.
Maurice VerStandig, Esq.
1452 W. Horizon Ridge Pkwy, #665
Henderson, NV 89012
Attorney for Plaintiff

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300 S. Fourth Street, Suite 1500
Las Vegas, Nevada 89101

FISHER & PHILLIPS LLP

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ORDER

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IT IS SO ORDERED:
____________________________________
UNITED STATES MAGISTRATE JUDGE

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September 8, 2021
DATED

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FP 41566857.1

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