Jacobson vs Rodriguez

Filing 19

ORDER granting 17 Stipulation - Discovery due by 1/22/2022. Motions due by 2/22/2022. Proposed Joint Pretrial Order due by 3/24/2022. Signed by Magistrate Judge Brenda Weksler on 11/23/2021. (Copies have been distributed pursuant to the NEF - DRS)

HOWARD & HOWARD ATTORNEYS PLLC

Case 2:20-cv-00797-APG-BNW Document 17 Filed 11/22/21 Page 1 of 3

1 L. Christopher Rose, Esq.
Nevada Bar No. 7500
2 Jonathan W. Fountain, Esq.
Nevada Bar No. 10351
3 HOWARD & HOWARD ATTORNEYS PLLC
3800 Howard Hughes Parkway, Suite 1000
4 Las Vegas, NV 89169
Tel. [phone]
5 Email: [e-mail]
Email: [e-mail]
6
K. Jon Breyer, Esq.
7 (Admitted pro hac vice)
Andrew R. Shedlock, Esq.
8 (Admitted pro hac vice)
KUTACK ROCK, LLP
9 60 South Sixth Street, Suite 3400
Minneapolis, MN 55402
10 Telephone: [phone]
Email: [e-mail]
11 Email: [e-mail]
12 Attorneys for Plaintiff Anthony S. Jacobson
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

15 ANTHONY S. JACOBSON, an individual,

Case No. 2:20-cv-00797-APG-BNW

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STIPULATION AND [PROPOSED]
ORDER TO AMEND CASE
MANAGEMENT DEADLINES

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Plaintiff,
vs.

18 ASTRED M. RODRIGUEZ, an individual,
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(First Request)

Defendant.

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4893-3078-6564.1

Case 2:20-cv-00797-APG-BNW Document 17 Filed 11/22/21 Page 2 of 3

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Pursuant to LR 26-3, Plaintiff ANTHONY S. JACOBSON (“Plaintiff” or “Jacobson”) and

2 Defendant ASTRED M. RODRIGUEZ (“Defendant” or “Rodriguez”) stipulate to amend the case
3 management deadlines, as follows:
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1.

A statement specifying the discovery completed. Plaintiff served its initial

5 disclosures on September 7, 2021. Plaintiff served an initial set of interrogatories, requests for
6 admissions, and requests for production on Defendant on September 20, 2021. Defendant served
7 written objections or responses to Plaintiff’s requests for admissions on November 3, 2021.
8 Defendant served its initial disclosures on November 4, 2021. Defendant served its written

HOWARD & HOWARD ATTORNEYS PLLC

9 objections and answers to Plaintiff’s interrogatories on November 10, 2021 and its written
10 objections to Plaintiff’s requests for the production of documents on November 15, 2021.
11 Defendant served its initial set of interrogatories and its initial set of requests for the production
12 of documents on Plaintiff on November 16, 2021.
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2.

A specific description of the discovery that remains to be completed. The

14 parties have agreed to limit the scope of all remaining discovery as follows: (a) Plaintiff will
15 respond to Defendant’s document requests but will only answer Defendant’s Interrogatories 1-6;
16 (b) the parties will each take the other party’s deposition remotely by videoconference; and (c)
17 the parties may subpoena third party AOM Holdings, LLC.
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3.

The reasons why the remaining discovery was not completed. During the

19 discovery period, the parties have focused their efforts on settlement rather than litigation. In
20 addition, the parties’ counsel encountered multiple scheduling conflicts that interfered with and
21 hindered their ability to conduct discovery. Moreover, good cause for the requested extension
22 exits so that the parties can develop the facts of their case so that it may be decided on the merits
23 rather than as a result of the application of a technical deadline. See, e.g., Foman v. Davis, 371
24 U.S. 178 (1962) (stating, in the context of a motion to amend the complaint, that: “It is . . . entirely
25 contrary to the spirit of the Federal Rules of Civil Procedure for decisions on the merits to be
26 avoided on the basis of such mere technicalities.”). Here, the parties agree that the foregoing
27 circumstances constitutes good cause for this first and short extension of the remaining case
28 management deadlines.
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Case 2:20-cv-00797-APG-BNW Document 17 Filed 11/22/21 Page 3 of 3

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4.

A proposed schedule for completing all remaining discovery. The parties

2 propose extending the discovery cutoff to January 22, 2022, the dispositive motion cutoff to
3 February 22, 2022, and the joint final pretrial order deadline to March 24, 2022.
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IT IS SO AGREED AND STIPULATED, this 19th day of November 2021:

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KUTACK ROCK, LLP

MARQUIS AURBACH COFFING

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By: /s/ K. Jon Breyer
K. Jon Breyer, Esq.
Andrew R. Shedlock, Esq.
60 South Sixth Street, Suite 3400
Minneapolis, MN 55402
Telephone: [phone]
Email: [e-mail]
Email: [e-mail]

By: /s/ Jennifer L. Micheli
Jennifer L. Micheli, Esq.
Nevada Bar No. 11210
10001 Park Run Drive
Las Vegas, NV 89145
Tel. [phone]
Email: [e-mail]

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HOWARD & HOWARD ATTORNEYS PLLC

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Attorneys for Defendant
Astred M. Rodriguez

HOWARD & HOWARD
ATTORNEYS PLLC
L. Christopher Rose, Esq.
Jonathan W. Fountain, Esq.
3800 Howard Hughes Parkway, Suite 1000
Las Vegas, NV 89169
Tel. [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff
Anthony S. Jacobson
IT IS SO ORDERED:

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___________________________________
UNITED STATES MAGISTRATE JUDGE

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November 23, 2021
DATED: ____________________________

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