Vidal et al v. Verizon Pension Plan for Associates et al

Filing 62

ORDER granting ECF No. 58 Stipulation : Proposed Joint Pretrial Order due by 8/26/2022; and the time for the Stipulating Parties to serve their initial Rule 26(a)(1) disclosures is extended to 9/30/2022. Signed by Magistrate Judge Brenda Weksler on 8/1/2022. (Copies have been distributed pursuant to the NEF - DRM)

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Case 2:22-cv-00274-ART-BNW Document 62 58 Filed 08/01/22 07/27/22 Page 1 of 4 5 IKENNA ODUNZE, ESQ. Nevada Bar No. 9885 ODUNZE & SWANIGAN ODUNZE PLLC 3651 Lindell Road Suite D #142 Las Vegas Nevada 89103 Telephone No. 702-943-0305 Facsimile No. 702-943-0233 Email: ipo.odunzeswanigalaw@gmail.com Attorneys for Plaintiffs MICHAEL A. VIDAL and ESTATE OF EVA RAMOS (through its Administrator JESSICA CLEMENTE) 1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 MICHAEL A. VIDAL, et al., 13 , Plaintiffs, 14 15 v. 17 VERIZON PENSION PLAN FOR ASSOCIATES, et al., , 18 Defendants. 16 Case No.: 2:22-cv-00274-ART-BNW STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR PARTIES TO COMPLY WITH LR 26-1(a) (FIRST REQUEST) 19 20 21 22 23 24 Now come Plaintiffs Michael A. Vidal and Estate of Eva Ramos (through its Administrator Jessica Clemente) (hereinafter collectively “Plaintiffs”), Conduent Incorporated, Conduent Business Services, LLC, Xerox Corporation, and Xerox HR Solutions, LLC (hereinafter collectively the “Conduent Defendants”), and Defendants Verizon Pension Plan for Associates, Verizon Employee 25 Benefits Committee, Kevin Cammarata, Verizon California Inc., Verizon Communications Inc., 26 Verizon Services Corp., and Verizon North. LLC, (hereinafter collectively the “Verizon 27 Defendants”) (the Verizon Defendants together with the Conduent Defendants are collectively 28 1 STIPULATION FOR EXTENSION DM3\8880940.1 Case 2:22-cv-00274-ART-BNW Document 62 58 Filed 08/01/22 07/27/22 Page 2 of 4 5 1 referred to as the “Served-Defendants”), and pursuant to Local Rules IA 6-1, 6-2, 7-2, Federal Rule 2 of Civil Procedure Rule 6, and any other applicable rule needed to effectuate this stipulation 3 4 5 6 (hereinafter this stipulation is referred to as the “Discovery-SAO”) hereby stipulate and agree concerning the above captioned case (Case No. 2:20-cv-00924-ART-BNW [hereinafter referred to as the “Case” or “instant matter”]) as follows: 7 WHEREAS, Plaintiffs filed an initial complaint (ECF No. 1) on February 14, 2022; 8 WHEREAS, Plaintiffs last amended their complaint (ECF No. 10; hereinafter referred to as 9 10 11 12 13 14 “SAC”) on March 8, 2022; WHEREAS, the Conduent Defendants and the Verizon Defendants filed motions to dismiss the SAC on June 17, 2022 (ECF Nos. 42 and 44 [hereinafter referred to as “MTDs”]); WHEREAS, pursuant to LR 26-1 and Fed. R. Civ. P 26 all parties that have appeared in the Case—including Conduent Defendants, Verizon Defendants and the Plaintiffs (hereinafter the 15 Conduent Defendants, Verizon Defendants and Plaintiffs are collectively referred to as the 16 “Stipulating Parties”)---held a Rule 26(f) conference (“26f Conference”) on July 14, 2022 and July 17 20, 2022; 18 19 20 21 22 WHEREAS, pursuant to LR 26-1, Fed. R. Civ. P. 26 and the Court’s previous order a proposed “stipulated discovery plan and scheduling order” is currently due on August 1, 2022; WHEREAS, there over a dozen Stipulating Parties and the aforesaid Stipulating Parties require more time for the completion of (and to comply with) LR 26-1(a)’s requirements; 23 WHEREAS, because of other litigation commitments (including but not limited to the 24 overlapping time needed to prepare and draft pleadings in this Case concerning the MTDs, inclusive 25 of the Plaintiffs drafting-and-preparing oppositions to the MTDs, and the Served-Defendants 26 27 28 drafting-and-preparing replies in support concerning their MTDs) of lead counsel for all of the Stipulating Parties, as well as a pre-existing prepaid and pre-scheduled family trip of lead counsel for 2 STIPULATION FOR EXTENSION DM3\8880940.1 Case 2:22-cv-00274-ART-BNW Document 62 58 Filed 08/01/22 07/27/22 Page 3 of 4 5 1 the Conduent Defendants the week of July 24, 2022, the Stipulating Parties have agreed to request 2 that the deadline for complying with LR 26-1(a) (which Rule includes a time for proposed 3 4 5 6 7 8 9 10 11 12 13 14 “discovery plan and scheduling order” and initial disclosures) be enlarged and extended such that the time for filing and submitting a proposed “stipulated discovery plan and scheduling order” be enlarged and extended from August 1, 2022 to August 26, 2022 to submit initial disclosures be modified and extended to September 30, 2022 for all the Stipulating Parties; WHEREAS this Discovery-SAO is made in good faith with good cause and not for the purpose of delay; WHEREAS, no prior extensions of the deadline to comply with LR 26-1(a) have been requested; WHEREAS, Fed. R. Civ. P. 6(b) requires the Court to approve the requested extension of time and therefore the Conduent Defendants, the Verizon Defendants and Plaintiffs collectively 15 request that the Court approve the stipulation, and HEREBY STIPULATE AND AGREE (and 16 respectfully request that the Court GRANT and ORDER the relief requested hereunder) as set forth 17 hereunder: 18 a. This is the Stipulating-Parties’ first stipulation for an enlargement of time to comply with 19 20 21 LR 26-1(a); b. That Stipulating Parties’ time to comply with LR 26-1(a) be enlarged as follows: (i) the time for the parties to file their proposed stipulated discovery plan and scheduling order be 22 23 extended until August 26, 2022 (if Stipulating Parties can not agree to a proposed stipulated 24 discovery plan and scheduling order on that date then they should submit competing 25 discovery plan and scheduling orders on that date); and (ii) the time for the Stipulating 26 Parties to serve their initial Rule 26(a)(1) disclosures be extended to September 30, 2022 27 28 3 STIPULATION FOR EXTENSION DM3\8880940.1 Case 2:22-cv-00274-ART-BNW Document 62 58 Filed 08/01/22 07/27/22 Page 4 of 4 5 1 2 3 4 5 6 7 8 9 10 c. This stipulation is made in good faith and not made for purposes of delay. IT IS SO STIPULATED. __/s/ Ikenna Odunze____ IKENNA ODUNZE Nevada Bar No. 9885 ODUNZE & SWANIGAN ODUNZE PLLC 3651 Lindell Road, Suite D #142 Las Vegas, NV 89103 Tele: 702.943.0305 E-Mail: ipo.odunzeswanigalaw@gmail.com Attorneys for Plaintiffs 11 12 13 /s/ Kyle J. Hoyt KYLE J. HOYT Nevada Bar No. 14886 JACKSON LEWIS P.C. 300 S. Fourth St., Suite 900 Las Vegas, NV 89101 Telephone: 702.9212457.2600 E-Mail: Kyle.Hoyt@jacksonlewis.com EDWARD D. PERRIN, JR. (pro hac vice motion to be filed) JENNIFER R. POE (pro hac vice motion to be filed) HALLETT & PERRIN 1445 Ross Ave., Suite 2400 Dallas, TX 15222-3112 Tele: 214.914.5150; E-Mail: eperrin@hallettperrin.com Attorneys for Defendants Conduent Incorporated, Conduent Business Services, LLC, Xerox Corporation, and Xerox HR Solutions, LLC 14 15 16 17 ORDER IT IS SO ORDERED 18 DATED: 10:41 am, August 01, 2022 19 20 BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28 4 STIPULATION FOR EXTENSION DM3\8880940.1

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